6/14/2021
E-Library - Information At Your Fingertips: Printer Friendly
company-designated physicians, prompting him to file a complaint for the payment of
total and permanent disability benefits.
In a Decision dated June 15, 2016, the Labor Arbiter ruled in favor of Utanes and
awarded him total and permanent disability benefits.[3] It was declared that TransGlobal is considered to have waived its right to assert nonliability for disability benefits
to Utanes because it continued to extend treatment despite the belated disclosure of
his existing Coronary Artery Disease. The treatment constitutes an implied admission of
compensability and work-relatedness of Utanes' lingering cardio-vascular illness.
Likewise, Trans-Global failed to issue a final assessment of Utanes' illness or fitness to
work, which failure deemed Utanes totally and permanently disabled.
On appeal, the National Labor Relations Commission (NLRC) affirmed the arbiter's
ruling because Utanes illness occurred within the duration of his contract, and his
treatment lasted for more than 120 days. Thus, the award of permanent total
disability
benefits
is justified.[4] Petitioners
moved
for reconsideration, but was
denied.[5]
Petitioners then filed a petition for certiorari with the CA, which dismissed the petition.
[6] Unsuccessful[7] at a reconsideration,[8] petitioners are seeking recourse before this
Court, alleging that the CA committed serious errors of law in upholding the NLRC's
Decision. Utanes is not entitled to permanent and total disability benefits and his other
monetary claims because of deliberate concealment of his coronary artery disease.[9]
For his part, Utanes maintains that he is entitled to total and permanent disability
benefits since his illness was work-related and had contributed to the development of
his condition that resulted in his disability.[10]
RULING
The petition is meritorious.
The general rule is that only questions of law may be raised in and resolved by this
Court on petitions brought under Rule 45 of the Rules of Civil Procedure, because the
Court, not being a trier of facts, is not duty-bound to reexamine and calibrate the
evidence on record.[11] Findings of fact of quasi-judicial bodies, especially when
affirmed by the CA, are generally accorded finality and respect.[12] There are, however,
recognized exceptions[13] to this general rule, such as the instant case, where there is
manifest mistake in the inference made from the findings of fact and judgment is based
on a misapprehension of facts.[14]
In the review of this case, we stress that entitlement of seafarers on overseas work to
disability benefits is a matter governed, not only by medical findings, but by law and by
contract. The material statutory provisions are Articles 197 to 199 of the Labor
Code[15] in relation to Section 2(a), Rule X of the Amended Rules on Employee
Compensation. By contract, the Philippine Overseas Employment Administration Standard Employment Contract (POEA-SEC), the parties' collective bargaining
https://elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/66745
2/9