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Moreover, petitioner insists that the company-designated physicians’ lack of any
finding that he was permanently disabled should not be made the basis of his actual
condition, considering that jurisprudence has held that the findings of the companydesignated physician should not be given credence when they cannot be established
as impartial.[31]
The Court’s Ruling
The petition lacks merit.
At the outset, it should be pointed out that from a perusal of petitioner’s arguments,
it is quite apparent that the petition raises questions of facts, inasmuch as this Court
is being asked to revisit and assess anew the factual findings of the CA and the
NLRC. Petitioner is fundamentally assailing the findings of the CA and the NLRC that
the evidence on record does not support his claim for permanent total disability
benefits. In effect, he would have the Court sift through, calibrate and re-examine
the credibility and probative value of the evidence on record so as to ultimately
decide whether or not there is sufficient basis to hold respondents accountable for
entirely/partially refusing to pay for his disability benefits. This clearly involves a
factual inquiry, the determination of which is the statutory function of the NLRC.[32]
The general rule is that the Court is not a trier of facts and this doctrine applies with
greater force in labor cases. Questions of fact are for the labor tribunals to
resolve.[33] Only errors of law are generally reviewed in petitions for review on
certiorari under Rule 45 of the Rules of Court.
In exceptional cases, however, the Court may be urged to probe and resolve factual
issues where there is insufficient or insubstantial evidence to support the findings of
the tribunal or the court below, or when too much is concluded, inferred or deduced
from the bare or incomplete facts submitted by the parties or, where the LA and the
NLRC came up with conflicting positions.[34] In this case, considering the conflicting
findings of the LA, on one hand, and the NLRC and the CA, on the other, the Court is
compelled to resolve the factual issues along with the legal ones, the core issue
being whether or not petitioner is entitled to disability benefits on account of his
medical condition.
The rule is that a seafarer’s right to disability benefits is a matter governed by law,
contract and medical findings. The relevant legal provisions are Articles 191 to 193
of the Labor Code and Section 2, Rule X of the Amended Rules on Employee
Compensation (AREC). The relevant contracts are the POEA-SEC, the collective
bargaining agreement, if any, and the employment agreement between the seafarer
and his employer.[35] Summarizing the interplay of these provisions as they relate to
the establishment of a seafarer’s claim to disability benefits, the Court, in Vergara v.
Hammonia,[36] wrote:
As these provisions operate, the seafarer, upon sign-off from his vessel,
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