4/9/2020
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In Culili v. Eastern Telecommunications Philippines, Inc.,[33] this Court explained:
While it is true that factual findings made by quasi-judicial and
administrative tribunals, if supported by substantial evidence, are accorded
great respect and even finality by the courts, this general rule admits of
exceptions. When there is a showing that a palpable and demonstrable
mistake that needs rectification has been committed or when the factual
findings were arrived at arbitrarily or in disregard of the evidence on record,
these findings may be examined by the courts.[34]
A perusal of the challenged decision before us will reveal that the Court of Appeals
actually sustained the factual findings of the tribunals below. However, it found itself
unable to affirm their rulings, in light of the applicable law on the matter. Thus, it was
compelled to go beyond the issue of grave abuse of discretion.
Main Issue: Entitlement of
Tomacruz to Disability Benefits
The core issue in this case is the propriety of the Court of Appeals’ award of disability
benefits to Tomacruz on the basis of the Labor Code provisions on disability, and
despite the company-designated physician’s declaration of his fitness to work.
The petitioners argue that the Court of Appeals erred in awarding disability benefits
despite the findings of the company-designated physician that Tomacruz was already fit
to work. Petitioners aver that the company- designated physician’s assessment and
evaluation of Tomacruz’s health condition should prevail over that of his doctor of
choice.[35] They cite Sarocam v. Interorient Maritime Ent., Inc.[36] to support this
contention.[37] Petitioners also asseverate that the Court of Appeals “seriously
erred”[38] in applying Article 192 of the Labor Code in this case. They claim that the
POEA SEC is the governing law between the parties[39] and the application of the Labor
Code provisions on disability is misplaced.[40]
Applicability of the Labor Code
Provisionson disability benefits to seafarers
Entitlement of seafarers to disability benefits is governed not only by medical findings
but also by contract and by law.[41] By contract, Department Order No. 4, series of
2000, of the Department of Labor and Employment (POEA SEC) and the parties’
Collective Bargaining Agreement bind the seafarer and the employer.[42] By law, the
Labor Code provisions on disability apply with equal force to seafarers.[43]
The petitioners are mistaken in their notion that only the POEA SEC should be
considered in resolving the issue at hand. The applicability of the Labor Code provisions
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