G.R. No. 199162. July 04, 2018 (Case Brief / Digest)

### Title: Phil-Man Marine Agency, Inc. and Dohle (IOM) Limited vs. Dedace, et al.
(A Review of Philippine Supreme Court Decision on Seafarer’s Disability Benefits)

### Facts:
1. **Contract Engagement and Duties:**
– On June 18, 2003, Phil-Man Marine Agency engaged Aniano P. Dedace, Jr. to work as an Able Seaman on M/V APL Shanghai for Dohle (IOM) Limited.
– Contract terms: 9 months duration, USD 465 monthly salary, USD 2.79/hr overtime, USD 78/month vacation leave.

2. **Illness Onset and Initial Medical Consultation:**
– January 2004: Dedace experienced pain in his lower abdomen and groin.
– February 20, 2004: Admitted to Gleneagles Maritime Medical Centre in Singapore, initially diagnosed with suspected liver haemangiomata and right kidney cyst.
– Further tests revealed Disseminated Sepsis with Multiple Liver Abscesses.

3. **Repatriation and Continued Medical Evaluations:**
– March 1, 2004: Dedace was repatriated to the Philippines and referred to Dr. Nicomedes G. Cruz.
– March 27, 2004: MRI by Dr. Cesar S. Co showed liver lesions and a right kidney lesion.
– May 20, 2004: Dr. Cruz concluded that Dedace’s illness was not work-related based on their gastroenterologist’s opinion.

4. **Denial of Compensation and Filing of the Claim:**
– June 7, 2004: Phil-Man informed Dedace that his illness was non-compensable and stopped payments.
– Dedace filed for permanent and total disability benefits with the National Labor Relations Commission (NLRC).

5. **Procedural Journey:**
– October 12, 2005: Labor Arbiter (LA) denied total disability benefits but awarded 30 days’ sickness allowance.
– March 6, 2007 & October 22, 2007: NLRC affirmed LA’s decision.
– Court of Appeals (CA) reversed NLRC’s decision, granting permanent total disability benefits, additional sickness allowance, and attorney’s fees.
– Petition for review filed with the Supreme Court challenging CA’s reversal.

### Issues:
1. **Whether the CA erred in awarding Dedace total permanent disability benefits despite contrary findings by the NLRC and LA.**
2. **Whether the CA erred in granting attorney’s fees to Dedace.**

### Court’s Decision:
**1. Permanent Total Disability Benefits:**
– **Work-Related Nature of Illness:**
– The Supreme Court upheld that the company failed to effectively dispute the presumption that Dedace’s illness was work-related.
– The company-designated physician did not issue a clear and conclusive medical assessment within the mandated 120-day period post-repatriation.
– **Medical Assessment and Evidence:**
– Dr. Cruz’s May 20, 2004 letter lacked specificity and failed to substantiate the claim of the illness being non-work-related.
– The failure to provide a comprehensive final assessment deemed Dedace totally and permanently disabled by default under the POEA-SEC.

**2. Attorney’s Fees:**
– The Supreme Court confirmed the award of attorney’s fees, asserting Dedace was forced to litigate to secure his rightful benefits.
– Legal principles: Under Article 2208 of the Civil Code and related labor laws, employees are entitled to attorney’s fees in cases involving recovery of wages and when litigating to protect legal rights.

### Doctrine:
**1. Presumption of Work-Relatedness:**
– Illnesses not listed under Section 32 of the POEA-SEC are disputably presumed work-related unless effectively countered by the employer.

**2. Medical Assessment Requirements:**
– The company-designated physician must provide a full and clear medical assessment within 120 days post-repatriation, failing which the seafarer is considered totally and permanently disabled.

**3. Attorney’s Fees:**
– Entitlement extends beyond cases of unlawful withholding of wages, applicable also where the employee must litigate to secure rights and benefits.

### Class Notes:
1. **Legal Presumptions:**
– Under POEA-SEC, non-listed illnesses are presumed work-related unless rebutted by substantial evidence from the employer.

2. **Employer’s Burden:**
– To rebut the presumption, the employer must provide clear, conclusive evidence from the company-designated physician within stipulated timelines.

3. **120-Day Rule:**
– Lack of a definitive medical assessment after 120 days results in automatic categorization of the seafarer’s condition as permanent and total disability.

4. **Attorney’s Fees Justification:**
– Granted when an employee is forced to litigation to enforce or protect their legal rights, encompassing actions aside from mere recovery of wages.

Terms (POEA-SEC): Sections 20(B), 32, 32-A outline conditions for compensability and the procedural obligations of employers and company-designated physicians.

### Historical Background:
– **Maritime Employment Law:**
– Seafarer contracts and disputes are governed by the 2000 POEA-SEC, designed to protect Filipino seafarers by standardizing terms and conditions, and establishing default presumptions in work-related injury or illness cases.
– **Labor Jurisprudence:**
– Case law emphasizes the necessity for employers to conclusively disprove the presumption of work-related illnesses to avoid automatic liability. Temporary to permanent disability classifications hinge on timely and definitive physician assessments.

This case reinforces systemic legal protections granted to Filipino seafarers under the POEA-SEC, underscoring the critical role of medical assessments and the procedural obligations of maritime employers.


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