G.R. No. 194758; October 24, 2012
RUBEN D. ANDRADA, Petitioner, vs. AGEMAR MANNING AGENCY, INC., and/or SONNET SHIPPING LTD./MALTA, Respondents.

FACTS

Petitioner Ruben D. Andrada was employed as a chief cook steward by respondents. During his contract in April 2004, he experienced severe abdominal pain while lifting heavy provisions. He was later diagnosed with umbilical hernia and gallbladder stones in the USA and was repatriated for treatment. In the Philippines, a company-designated physician recommended and performed successful surgery. Post-operation, the company doctor certified Andrada as “fully recovered” and “fit to work” in March 2005. Andrada subsequently executed a Deed of Release, Waiver, and Quitclaim upon receiving a monetary settlement.
Notwithstanding the settlement and the company doctor’s certification, Andrada consulted his personal physician, Dr. Vicaldo, who assessed him with a Grade VIII disability and declared him unfit for sea duty, opining that his illness was work-related. Based on this, Andrada filed a complaint for disability benefits, arguing his inability to work for over 120 days constituted permanent total disability. The Labor Arbiter ruled in his favor, giving more weight to his personal doctor’s assessment.

ISSUE

Whether petitioner Ruben D. Andrada is entitled to permanent total disability benefits despite being certified as fit to work by the company-designated physician and having executed a quitclaim.

RULING

No. The Supreme Court denied the petition and affirmed the rulings of the NLRC and Court of Appeals which dismissed Andrada’s claim. The legal logic rests on the primacy of the company-designated physician’s assessment under the POEA-SEC, absent any evidence of arbitrariness or bad faith. The certification of fitness to work issued by the company doctor, who supervised Andrada’s treatment, was deemed conclusive on his medical status. The Court emphasized that the mere opinion of a seafarer’s personal physician cannot override the assessment of the company-designated physician, especially when the latter’s findings are supported by the seafarer’s subsequent execution of a quitclaim after receiving consideration.
Furthermore, the Court found the quitclaim valid, as it was executed voluntarily for a reasonable amount without any evidence of deceit or coercion. The claim of permanent total disability was unsubstantiated, as the company physician’s certification definitively established Andrada’s recovery and fitness for work. Therefore, with no credible proof of continuing disability, his claim for benefits had no legal basis.