Coastal Safeway v. Esguerra
G.R. No. 185352 (August 10, 2011)
Facts:
Elmer T. Esguerra (Esguerra), a seafarer since 1991, applied for placement with Coastal Safeway Marine Services, Inc. (CSMSI) in 2003. He was found fit for work during a pre-employment medical examination and was subsequently hired as a Third Mate for the M/V Mr. Nelson, an ocean-going vessel. However, he ended up boarding the M/V Gondwana on May 13, 2003. After 46 days of service, Esguerra experienced back and chest pains and sought medical attention while the vessel was docked in Jebel Ali, UAE. On July 5, 2003, he was declared unfit for work pending a complete cardiac evaluation.
Despite normal test results, Esguerra insisted on repatriation due to his unfitness for work and alleged non-payment of his salary. He returned to the Philippines on July 7, 2003, and sought medical treatment at various hospitals. On July 16, 2003, he filed a complaint against CSMSI, its president, and the foreign principal, Canada and Middle East General Trading (CMEGT), for medical reimbursement, sickness allowance, and disability benefits.
Esguerra's medical evaluations in the Philippines led to diagnoses of "Coronary Artery Disease, Stable Angina Pectoris" and an Impediment Grade VII (41.8%). He claimed that CSMSI failed to refer him to a company-designated physician, which led him to seek medical attention independently. CSMSI, on the other hand, argued that Esguerra was fit for work based on the medical tests conducted in UAE and that he failed to comply with the mandatory requirement of undergoing a post-employment medical examination within three working days of his return.
The Labor Arbiter dismissed Esguerra's complaint, stating he did not prove his disability and failed to submit to a post-employment medical examination. The NLRC affirmed this decision. Esguerra then filed a petition for certiorari with the Court of Appeals, which reversed the NLRC's decision, ordering CSMSI to pay Esguerra his sickness allowance and disability benefits.
Issues:
- Whether the Court of Appeals erred in reversing the findings of the Labor Arbiter and the NLRC.
- Whether the application of the POEA Standard Employment Contract of 1996 was appropriate instead of the Revised Terms and Conditions for Seafarers on Board Ocean-Going Vessels.
Arguments:
Petitioner (CSMSI):
- The Court of Appeals misapprehended the evidence and incorrectly applied the 1996 POEA-SEC instead of the 2000 version, which was applicable to Esguerra's contract.
- Esguerra failed to comply with the mandatory reporting requirement of submitting to a post-employment medical examination within three days of his return, which should result in the forfeiture of his claims for benefits.
Respondent (Esguerra):
- Esguerra argued that he was repatriated for medical reasons and that CSMSI's failure to refer him to a company-designated physician justified his actions in seeking medical attention independently.
- He contended that the medical certifications from his doctors in the Philippines supported his claims for disability benefits and sickness allowance.
Court's Ruling:
The Supreme Court granted the petition, reversing the Court of Appeals' decision. The Court emphasized that the 2000 POEA-SEC was applicable to Esguerra's employment contract. It reiterated that under Section 20-B of the POEA-SEC, a seafarer must submit to a post-employment medical examination by a company-designated physician within three working days of repatriation, unless physically incapacitated.
The Court found that Esguerra did not provide sufficient evidence to justify his failure to comply with this requirement. His claims were based on medical certifications that lacked adequate supporting diagnostic tests to refute the findings from the Jebel Ali Medical Centre, which indicated he was fit for work. The Court concluded that the absence of compliance with the mandatory reporting requirement led to the forfeiture of Esguerra's claims for disability benefits and sickness allowance.
Legal Principles Established:
- The 2000 POEA-SEC governs the employment contracts of Filipino seafarers and includes mandatory reporting requirements for claims of disability benefits and sickness allowances.
- A seafarer’s failure to comply with the mandatory reporting requirement without justifiable cause results in the forfeiture of the right to claim benefits.
- Medical assessments by company-designated physicians are critical in determining a seafarer's entitlement to disability benefits, and the burden of proof lies with the claimant to establish compliance with procedural requirements.