In Maersk Filipinas Crewing Inc. v. Joselito R. Ramos, the Supreme Court affirmed that a seafarer is entitled to disability compensation even if the injury results in permanent partial disability, impacting their earning capacity. The Court emphasized that disability refers to the loss or impairment of earning capacity, not just the physical injury itself. This ruling ensures that seafarers who suffer work-related injuries receive the compensation they deserve, even if they are not completely incapacitated, thereby upholding the protective spirit of labor laws and safeguarding the welfare of Filipino seamen.

A Screw to the Eye: When Can a Seafarer Claim Disability Benefits?

Joselito Ramos, an able seaman for Maersk, suffered an eye injury while on board a vessel. After being hit by a screw, his left eye sustained a corneal scar and cystic macula. He was repatriated and underwent medical treatment, but his vision did not fully recover. Despite the company-designated physician initially stating he could return to work with corrective glasses, another doctor found him unable to perform tasks requiring good vision. The central legal question became: Is Ramos entitled to disability benefits even if he isn’t completely unable to work?

The case navigated through the Labor Arbiter (LA), the National Labor Relations Commission (NLRC), and the Court of Appeals (CA) before reaching the Supreme Court. The LA initially dismissed Ramos’ complaint, stating that the parties should comply with the POEA Standard Contract regarding a third doctor’s opinion when disagreements arise between the seafarer’s and company-designated physicians. However, the NLRC reversed this decision, awarding Ramos disability compensation, moral and exemplary damages, and attorney’s fees. The CA affirmed the NLRC’s findings but removed the moral and exemplary damages.

Before the Supreme Court, Maersk argued that Ramos’ counsel lacked authority to represent him after the LA’s decision and that Ramos failed to perfect his appeal to the NLRC on time. They also contended that Ramos’ injury wasn’t permanent and that he was certified fit to work by the company physician. However, the Supreme Court sided with Ramos on all issues.

First, the Court addressed the issue of legal representation. According to Section 21, Rule 138 of the Rules of Court:

SEC. 21. Authority of attorney to appear. – An attorney is presumed to be properly authorized to represent any cause in which he appears, and no written power of attorney is required to authorize him to appear in court for his client, but the presiding judge may, on motion of either party and on reasonable grounds therefor being shown, require any attorney who assumes the right to appear in a case to produce or prove the authority under which he appears, and to disclose, whenever pertinent to any issue, the name of the person who employed him, and may thereupon make such order as justice requires. An attorney willfully appearing in court for a person without being employed, unless by leave of the court, may be punished for contempt as an officer of the court who has misbehaved in his official transactions.

The Court found that Ramos’ mere denial of his counsel’s authority was insufficient to overcome the presumption of proper representation. Furthermore, Ramos’ attempt to disavow his counsel came almost four years after the LA’s dismissal, and after the NLRC had already ruled in his favor, which the court considered suspect.

Next, the Court addressed the timeliness of Ramos’ appeal. While Ramos’ counsel missed the filing deadline due to the NLRC office closing early because of a jeepney strike, the Court emphasized that procedural rules can be relaxed to ensure due process. This flexibility is crucial in labor cases, where the rights of workers are at stake. The NLRC’s decision to allow the appeal filed on the next working day was deemed just and fair.

Finally, the Court addressed the core issue of disability compensation. The Court clarified that disability refers to the impairment of earning capacity, not just the physical injury. The Court highlighted the definition of partial permanent disability from Section 2 of Rule VII of the Amended Rules on Employees’ Compensation:

(c) A disability is partial and permanent if as a result of the injury or sickness the employee suffers a permanent partial loss of the use of any part of his body.

Even though Dr. Dolor certified Ramos fit to work, he also acknowledged that Ramos’ left eye could not be further improved. The initial diagnosis already indicated a 30% disability in his left eye. The Court emphasized that despite the subsequent cataract surgery, Ramos was unable to work as a seaman for roughly two years, resulting in a loss of earning capacity.

The Court also addressed Maersk’s argument that the POEA Standard Employment Contract only provides compensation for at least 50% vision loss. The Court stated that the POEA Standard Employment Contract was primarily for the protection of Filipino seamen and must be construed liberally in their favor. Furthermore, the Court cited Section 20.B.4 of the POEA Standard Employment Contract:

[t]hose illnesses not listed in Section 32 of this Contract are disputably presumed as work related.

The Court concluded that the disability schedule contemplates injuries not explicitly listed. Thus, Ramos was entitled to compensation despite his injury not being specifically listed in the POEA contract.

The Court affirmed the NLRC’s computation of disability benefits. The applicable CBA between AMOSUP and Maersk Company (IOM) provided a rate of compensation of US$60,000.00 for 100% disability. Since Ramos suffered a Grade 12 impediment (30% vision loss), he was entitled to 10.45% of the maximum rate, amounting to US$6,270.00. The court highlighted Section 20.1.5 of the CBA regarding 100% compensation for less than 50% disability, noting it required company doctor certification of permanent unfitness for sea service, which was absent here.

Regarding attorney’s fees, the Court affirmed the CA’s decision, citing Article 2208(2) of the Civil Code, which allows for attorney’s fees in actions for indemnity under workmen’s compensation and employer liability laws.

FAQs

What was the key issue in this case?	The key issue was whether a seafarer is entitled to disability compensation for a permanent partial disability that impairs their earning capacity, even if they are not completely unable to work.
What did the Supreme Court rule?	The Supreme Court ruled in favor of the seafarer, affirming that he was entitled to disability compensation because the injury impaired his earning capacity as a seaman, despite not being completely incapacitated.
What is the significance of a "company-designated physician"?	The company-designated physician is the doctor chosen by the employer to assess the seafarer’s medical condition. Their assessment is important in determining disability benefits, but it is not the only factor considered by the courts.
What does "permanent partial disability" mean in this context?	Permanent partial disability refers to a situation where an employee suffers a permanent loss of the use of a part of their body, which prevents them from continuing with their former work, but does not render them completely disabled.
How is disability compensation calculated in this case?	Disability compensation was calculated based on the CBA between AMOSUP and Maersk Company (IOM), which provided a rate for 100% disability, with pro-rata compensation for lesser disabilities, in this case, 10.45% for a Grade 12 impediment.
Why was attorney’s fees awarded?	Attorney’s fees were awarded because the seafarer was compelled to litigate to protect his interests and recover benefits rightfully due to him under workmen’s compensation and employer liability laws.
What is the POEA Standard Employment Contract?	The POEA Standard Employment Contract is a standard contract designed to protect Filipino seamen working on ocean-going vessels, ensuring fair terms and conditions of employment, including provisions for disability compensation.
What if my injury isn’t listed in the POEA Standard Employment Contract?	Injuries not explicitly listed in the POEA Standard Employment Contract are still presumed to be work-related, meaning you may still be entitled to compensation even if your specific injury isn’t mentioned.

The Maersk Filipinas case reinforces the principle that labor laws are designed to protect workers, especially seafarers who face unique risks in their profession. The ruling ensures that seafarers receive just compensation for injuries that impair their earning capacity, even if they are not completely disabled, solidifying the protective nature of Philippine labor laws and promoting the welfare of Filipino seamen.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Maersk Filipinas Crewing Inc., and Maersk Co. IOM Ltd. v. Joselito R. Ramos, G.R. No. 184256, January 18, 2017