G.R. No. 244437 , September 14, 2020
HEIRS OF AMADEO ALEX G. PAJARES, ET AL., PETITIONERS, VS. NORTH SEA MARINE SERVICES CORPORATION, ET AL., RESPONDENTS.

FACTS

Amadeo Alex G. Pajares was employed as a Suite Attendant by North Sea Marine Services Corporation. During his contract, he suffered severe nose bleeding, was declared unfit for duty, and was repatriated. In the Philippines, the company-designated physician diagnosed him with Multiple Myeloma, a blood cancer, and deemed it not work-related. Amadeo later consulted an independent physician who declared him unfit for sea service. He requested a third medical opinion and copies of his medical records from the company, but these were denied. He died during the pendency of the case, and his heirs pursued a claim for total and permanent disability benefits.
The Panel of Voluntary Arbitrators dismissed the complaint, upholding the company-designated physician’s finding that the illness was not work-related. However, it awarded US$20,000 as financial assistance on grounds of social justice. The Court of Appeals affirmed the denial of disability benefits but reduced the financial assistance to US$8,500, noting the company’s alleged prior offer of this amount and Amadeo’s years of satisfactory service.

ISSUE

Whether the petitioners are entitled to disability benefits and/or financial assistance.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the petitioners were not entitled to disability benefits. The legal logic centered on procedural and substantive grounds. Procedurally, the petitioners failed to appeal the Panel of VAs’ decision denying disability benefits to the CA. Under the doctrine of immutability of judgment and the rule that a party who does not appeal cannot obtain affirmative relief, the Court could not review or reverse the denial of disability benefits, as these issues were not properly elevated.
Substantively, the Court upheld the award of financial assistance as a matter of equitable discretion and compassionate justice. While disability benefits require proof of work-relatedness, financial assistance can be granted on humanitarian grounds considering the employee’s length of satisfactory service and the circumstances of his separation due to illness. The Court found the reduction to US$8,500 appropriate, as it reflected the company’s prior offer and was a reasonable equitable concession under the circumstances, despite the lack of entitlement to statutory benefits. The ruling reinforces that financial assistance is a discretionary, ex gratia remedy distinct from compensatory disability claims.