G.R. No. 206178 . August 09, 2017.
PEDRO C. PEREA, PETITIONER, VS. ELBURG SHIPMANAGEMENT PHILIPPINES, INC., AUGUSTEA ATLANTICA SRL/ITALY, AND CAPTAIN ANTONIO S. NOMBRADO, RESPONDENTS.

FACTS

Petitioner Pedro C. Perea was hired as a fitter by respondent Elburg Shipmanagement Philippines, Inc. On May 15, 2010, while aboard the vessel MV Lemno, he experienced difficulty breathing and chest pains. Following an explosion incident days later, he also suffered injuries to his shoulder and fingers. He was subsequently repatriated to the Philippines on May 31, 2010. The company-designated physicians, Dr. Karen Hao-Quan and Dr. Robert D. Lim, conducted a series of examinations and treatments. On November 5, 2010, they issued a final assessment clearing Perea of the injuries that caused his repatriation and finding him fit to work. Perea, however, consulted his personal physician, Dr. Antonio Pascual, who diagnosed him with uncontrolled hypertension and coronary artery disease and declared him medically unfit for sea duty.
Perea filed a complaint for permanent total disability benefits. The Labor Arbiter dismissed the complaint, giving more weight to the findings of the company-designated physicians. The National Labor Relations Commission affirmed this decision, additionally noting Perea’s alleged failure to disclose a pre-existing elbow condition. The Court of Appeals sustained the rulings, prompting Perea to elevate the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

The core issue is whether the Court of Appeals erred in affirming the dismissal of Perea’s claim for permanent total disability benefits, thereby upholding the credibility of the company-designated physicians’ fit-to-work assessment over his personal doctor’s contrary opinion.

RULING

The Supreme Court denied the petition and affirmed the assailed Court of Appeals resolutions. The Court emphasized the principle that in disability compensation claims, the assessment of the company-designated physician enjoys a presumption of correctness, provided it is supported by sufficient medical evidence and issued within the mandated periods. The company doctors, Dr. Hao-Quan and Dr. Lim, closely monitored and treated Perea for nearly five months, conducting extensive tests including a coronary angiogram. Their final, categorical fit-to-work certification was issued within the 240-day extended treatment period allowed by law, was based on objective findings, and was not shown to be arbitrary or biased.
In contrast, Dr. Pascual’s assessment was based on a single consultation. The Court held that the physician with personal knowledge gained from prolonged and consistent treatment is more credible than one who conducted a lone examination. The Court also found that Perea’s hypertension, absent proof it resulted in organ impairment as required by the POEA Contract, was not compensable. The NLRC’s finding on non-disclosure was deemed a superfluity, as the core ruling on the credibility of medical assessments was sufficient to dispose of the claim. The labor tribunals’ factual findings, when supported by substantial evidence, are accorded respect and finality.