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board MV Star Princess.
Respondent’s Position
Laurel, in his Compliance and Manifestation with Comment to Petitioners’ Petition for
Review on Certiorari,[20] counters that his illness is compensable because it was
acquired during the effectivity of his employment contract while performing his work
aboard the petitioners’ vessel. The fact that Grave’s Disease may be hereditary does
not bar him from entitlement to disability benefits. Compensability does not require
that employment be the sole cause of the illness. It is enough that there exists a
reasonable work connection. The strenuous condition of his employment on board the
MV Star Princess triggered the development of his hyperthyroidism due to his exposure
to varying temperature and chemical irritants. Contrary to the petitioners’ contention,
Laurel asserts that the burden of proof rests on the petitioners by virtue of the
presumption of compensability under Section 32 of the POEA contract.
Laurel likewise contends that the jurisdiction of the Court in cases brought before it
from the CA by way of petition for review on certiorari under Rule 45 of the Revised
Rules of Court is limited to reviewing errors of law, and that findings of fact of the latter
are conclusive. Specifically, Laurel cited the case of Palomado v. National Labor
Relations Commission,[21] in stating the fundamental rule that the factual findings of
quasi-judicial agencies like the NLRC if supported by substantial evidence are generally
accorded not only great respect but even finality, and are binding upon the Court,
unless the petitioner is able to show that the NLRC arbitrarily disregarded evidence
before it or misapprehended evidence to such an extent as to compel a contrary
conclusion if such evidence were to be properly appreciated. In this case, according to
him, the CA correctly affirmed the finding of the NLRC that Laurel was entitled to
disability compensation and other charges.
The Court’s Ruling
A perusal of the petitioners’ arguments discloses that the issues raised are essentially
factual in nature. Generally, factual issues are not proper subjects of the Court’s power
of judicial review.
It is elementary that this Court is not a trier of facts and this rule applies with greater
force in labor cases. Questions of fact are for the labor tribunals to resolve. Only errors
of law are generally reviewed in petitions for review on certiorari criticizing the
decisions of the CA. Indeed, findings of fact of quasi-judicial bodies like the NLRC, as
affirmed by the CA, are generally conclusive on this Court. In exceptional cases,
however, the Court may be urged to probe and resolve factual issues when 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.[22] The present case clearly falls within these exceptions as the finding of the
LA, on one hand, conflicts with those of the NLRC and the CA, on the other.
The
Court,
nevertheless,
finds
elibrary.judiciary.gov.ph/thebookshelf/showdocsfriendly/1/55780
for
respondent
Laurel,
and
resolves
that
his
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