In this case, the Supreme Court clarified the burden of proof for seafarers claiming disability benefits and underscored the importance of the company-designated physician’s assessment. The Court ruled that while a seafarer’s illness was acknowledged, the evidence did not support a claim for permanent total disability, limiting the compensation to a partial disability grading based on the company doctor’s evaluation.

Knee Injury or Skin Condition: Whose Medical Opinion Prevails in a Seafarer’s Disability Claim?

The case of Maunlad Trans Inc. v. Gabriel Isidro revolves around a seafarer, Gabriel Isidro, who sought full disability benefits from his employer, Maunlad Trans Inc., and its foreign principal, Carnival Cruise Lines. Isidro claimed he suffered a knee injury while working on board a vessel, as well as a skin condition diagnosed as psoriasis. The central legal question is whether Isidro is entitled to full disability benefits or only partial disability compensation based on the medical assessments made by the company-designated physician.

The factual backdrop begins with Isidro’s employment as a bartender. During his employment, he experienced both a knee injury and a skin condition. Upon repatriation, he was examined by a company-designated physician who primarily focused on his skin condition, psoriasis, and eventually issued a disability grading of Grade 12. Meanwhile, Isidro consulted his own doctor who assessed him as unfit to work due to both psoriasis and the knee injury. This conflicting medical assessment led to a dispute over the extent of disability benefits Isidro was entitled to receive.

The Labor Arbiter (LA) initially awarded compensation equivalent to Grade 12 disability. However, the National Labor Relations Commission (NLRC) modified this decision, granting full disability compensation benefits. The Court of Appeals (CA) affirmed the NLRC’s ruling. The Supreme Court, however, disagreed with the CA and NLRC, leading to a re-examination of the facts and evidence.

The Supreme Court emphasized that in disability claims, the burden of proof rests on the seafarer to substantiate their claim with substantial evidence. As the Court stated, the seafarer’s claim, “cannot rest on mere speculations, presumptions or conjectures.” This means that the seafarer must present concrete evidence to support the existence and extent of their disability. In Isidro’s case, the Court found that he did not adequately prove his entitlement to full and permanent disability benefits for his alleged knee injury.

While the CA and NLRC acknowledged the existence of Isidro’s knee injury, the Supreme Court noted that this injury was not the primary reason for his medical treatment upon repatriation. The Court observed that Isidro did not consistently complain about the knee injury to the company-designated physician. Additionally, the medical reports mainly detailed the progress of his skin condition, psoriasis. The court stated:

That respondent did not complain of, and was not treated for, the alleged knee injury is evident from the medical reports submitted by the company-designated physician detailing the progress of respondent’s skin condition.

This lack of consistent reporting and treatment for the knee injury weakened Isidro’s claim for full disability benefits based on that particular ailment. The Court also questioned the credibility of the medical certification issued by Isidro’s chosen doctor, Dr. Jacinto. The Court emphasized that Dr. Jacinto’s examination occurred only once, four months after Isidro’s repatriation. Moreover, the Court noted the absence of crucial supporting evidence, such as MRI results, that would validate the existence and severity of the alleged knee injury. Without such evidence, the Court found it difficult to give credence to Dr. Jacinto’s assessment.

In contrast, the Supreme Court gave greater weight to the medical findings of the company-designated physician who had continuously monitored and treated Isidro’s psoriasis. The Court reasoned that doctors with firsthand knowledge and regular monitoring of a seafarer’s condition are better positioned to assess the disability. This principle is highlighted in the case Dalusong v. Eagle Clare, Shipping, Inc., where the Supreme Court stated that “the doctor who have had a personal knowledge of the actual medical condition, having closely, meticulously and regularly monitored and actually treated the seafarer’s illness, is more qualified to assess the seafarer’s disability.”

The company-designated physician, along with a dermatologist, had treated Isidro for months, providing a more comprehensive assessment of his condition. Given this, the Court upheld the disability grading of 12 issued by the company-designated physician for Isidro’s psoriasis. The CA had disregarded this grading because it was released on the 223rd day after repatriation, but the Supreme Court clarified the application of the 120-day and 240-day rule. The Court cited Vergara v. Hammonia Maritime Services, Inc., clarifying that the maximum 240-day rule applies if the extension is due to the seaman requiring further medical attention.

The Court stated:

As these provisions operate, the seafarer, upon sign-off from his vessel, must report to the company-designated physician within three (3) days from arrival for diagnosis and treatment. For the duration of the treatment but in no case to exceed 120 days, the seaman is on temporary total disability as he is totally unable to work. He receives his basic wage during this period until he is declared fit to work or his temporary disability is acknowledged by the company to be permanent, either partially or totally, as his condition is defined under the POEA Standard Employment Contract and by applicable Philippine laws. If the 120 days initial period is exceeded and no such declaration is made because the seafarer requires further medical attention, then the temporary total disability period may be extended up to a maximum of 240 days, subject to the right of the employer to declare within this period that a permanent partial or total disability already exists. The seaman may of course also be declared fit to work at any time such declaration is justified by his medical condition.

The Supreme Court also addressed the issue of attorney’s fees. The Court found no evidence of bad faith on the part of the petitioners, who had consistently offered compensation equivalent to a Grade 12 disability. Since Isidro had refused to accept this offer without justifiable reason, the Court deemed the award of attorney’s fees unwarranted.

FAQs

What was the key issue in this case?	The key issue was whether the seafarer, Gabriel Isidro, was entitled to full disability benefits or only partial disability compensation based on the medical assessments of his knee injury and psoriasis. The court examined whether his condition warranted a higher compensation than what was initially offered.
What did the company-designated physician diagnose?	The company-designated physician diagnosed Isidro with psoriasis vulgaris and issued a disability grading of Grade 12 for slight residual disorder. The physician primarily focused on treating and monitoring his skin condition throughout the medical treatment period.
What was the significance of the 120/240-day rule?	The 120/240-day rule refers to the period during which a seafarer is under temporary total disability and receives medical treatment. The Supreme Court clarified that if treatment extends beyond 120 days, the period can be extended up to 240 days, within which the employer can declare a permanent disability.
Why was the private doctor’s opinion given less weight?	The private doctor’s opinion was given less weight because the examination occurred only once, four months after Isidro’s repatriation, and lacked supporting evidence like MRI results. The court prioritized the assessment of the company-designated physician who had continuously monitored Isidro’s condition.
What evidence did the seafarer lack in his claim?	The seafarer lacked consistent medical complaints and treatment records for his alleged knee injury upon repatriation. Crucial supporting evidence, such as MRI results or detailed medical assessments, was missing to validate the severity and persistence of the knee injury.
How did the Supreme Court apply the burden of proof?	The Supreme Court emphasized that the burden of proof rests on the seafarer to establish their disability claim with substantial evidence. The court found that Isidro did not provide sufficient evidence to support his claim for full and permanent disability benefits for his knee injury.
What is the basis for awarding attorney’s fees?	Attorney’s fees are typically awarded when there is evidence of bad faith on the part of the employer. In this case, the Supreme Court found no bad faith because the petitioners had consistently offered compensation equivalent to a Grade 12 disability.
What was the final ruling of the Supreme Court?	The Supreme Court reversed the CA and NLRC decisions, ruling that Isidro was only entitled to permanent and partial disability benefits equivalent to Grade 12, based on the company-designated physician’s assessment of his psoriasis. The award of attorney’s fees was also reversed.

In conclusion, the Supreme Court’s decision in Maunlad Trans Inc. v. Gabriel Isidro underscores the importance of the company-designated physician’s role in assessing seafarer’s disabilities and the seafarer’s responsibility to provide substantial evidence to support their claims. This ruling provides clarity on the application of the 120/240-day rule and the weight given to medical assessments in disability claims.

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: MAUNLAD TRANS INC., VS. GABRIEL ISIDRO, G.R. No. 222699, July 24, 2017