In his Comment,[17] the respondent claims that the company-designated
physician had no factual basis in ruling that his illness was not work-related. He
posits that the opinions of company-designated physicians should not be taken as
gospel truth because of their non-independent nature. Finally, he claims that his
illness could have only been acquired on board since he passed the company’s
PEME.
THE COURT’S RULING
We find the petition meritorious.
The petitioners essentially claim that the evidence on record does not support
the findings of the labor tribunals and the CA that the respondent’s illness was
work-related. This argument clearly involves a factual inquiry whose determination
is not a function of this Court. We emphasize, however, that we are reviewing in
this Rule 45 petition the decision of the CA on a Rule 65 petition filed by the
petitioners with that court. In so doing, we review the legal correctness of the CA
decision from the prism of whether it correctly determined the presence or absence
of grave abuse of discretion in the NLRC decision before it.
In this task, the Court is allowed, in exceptional cases, to delve into and
resolve factual issues when insufficient or insubstantial evidence to support the
findings of the tribunal or court below is alleged, or when too much is concluded,
inferred or deduced from the bare and incomplete facts submitted by the parties, to
the point of grave abuse of discretion.[18] The present case constitutes one of these
exceptional cases.
The Rule on Disability Benefits
Entitlement of seamen 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 191 to 193 under Chapter VI (Disability Benefits)
of the Labor Code, in relation with Rule X of the Rules and Regulations
Implementing Book IV of the Labor Code. By contract, the POEA-SEC, as
provided under Department Order No. 4, series of 2000 of the Department of Labor