G.R. No. 241857, June 17, 2019
CAREER PHILS. SHIPMANAGEMENT, INC., CMA SHIPS UK LIMITED, AND SAMPAGUITA D. MARAVE, Petitioners, vs. JOHN FREDERICK T. TIQUIO, Respondent.

FACTS

Respondent John Frederick T. Tiquio was hired as an ordinary seaman by petitioners on November 14, 2012. On June 17, 2013, while on board the vessel, he fell ill with high fever, nausea, and vomiting. He was medically repatriated on June 29, 2013, after being diagnosed with hyperthyroidism at an offshore clinic in France. Upon repatriation, the company-designated physician (CDP), Dr. Jay S. Fonte, diagnosed him with hyperthyroidism secondary to Graves’ Disease. Tiquio underwent medical treatment for approximately one year. On June 23, 2014, Dr. Fonte issued a certification stating Tiquio was still unfit for work, recommended repeat radioactive iodine therapy, and opined that his illness was “NOT Work Oriented.”
On September 1, 2014, Tiquio filed a complaint for disability benefits, claiming his illness rendered him unable to work and was work-related. Initially, he did not submit a contrary medical opinion from his own doctor. In their defense, petitioners relied on the CDP’s assessment that Graves’ Disease is an autoimmune illness not work-oriented and argued Tiquio failed to observe the conflict-resolution procedure under the POEA-SEC. Subsequently, in a Rejoinder dated December 16, 2014, Tiquio attached a medical certificate from Dr. Amado M. San Luis, a neurosurgeon, dated December 3, 2014, which declared him permanently incapacitated for sea duty and that his illness was work-related.
The Labor Arbiter (LA) granted Tiquio’s claim, awarding total and permanent disability benefits. The National Labor Relations Commission (NLRC) reversed the LA, dismissing the complaint. The NLRC held that Tiquio’s complaint was prematurely filed because at the time of its filing, he had not yet secured a contrary medical opinion from his own doctor to trigger a conflict with the CDP’s assessment, and he failed to refer the conflict to a third doctor as required by the POEA-SEC. The Court of Appeals (CA) reinstated the LA’s decision, ruling that Tiquio’s illness was work-related and compensable.

ISSUE

Whether the Court of Appeals erred in awarding total and permanent disability benefits to Tiquio despite his failure to comply with the mandatory conflict-resolution procedure under Section 20(A)(3) of the POEA-SEC.

RULING

The Supreme Court granted the petition and reversed the CA decision, thereby reinstating the NLRC’s dismissal of the complaint. The Court held that Tiquio failed to comply with the mandatory procedure for resolving conflicting medical assessments, which is a condition precedent for claiming disability benefits.
The Ratio Decidendi is anchored on the strict application of the conflict-resolution mechanism under the POEA-SEC, which is deemed integral to the seafarer’s right to claim disability benefits. The Court emphasized that the procedure under Section 20(A)(3) of the POEA-SEC is mandatory, not merely directory. This provision requires that if the seafarer disagrees with the CDP’s assessment, he must seek a second opinion from his own doctor. The employer is then obligated to mutually agree with the seafarer on the choice of a third doctor whose decision shall be final and binding. Non-compliance with this procedure renders the seafarer’s claim for disability benefits premature and without basis.
In this case, Tiquio filed his complaint on September 1, 2014, based solely on the CDP’s certification that he was unfit and that his illness was not work-related. He did not yet possess a contrary medical opinion from his own physician at that time. The conflicting opinion from Dr. San Luis was obtained only on December 3, 2014, and submitted in December 2014, which was months after the complaint was initiated. Therefore, at the time of filing, there was no actual conflict of medical assessments to speak of. The Court ruled that a seafarer cannot unilaterally determine that a conflict exists and proceed to litigation without first undergoing the prescribed procedure. By filing the complaint prematurely, Tiquio deprived the petitioners of their right to have the medical dispute resolved by a third, independent physician, as stipulated in their contract. Consequently, his claim for disability benefits could not prosper. The Court also noted that the medical opinion of Dr. San Luis, a neurosurgeon, was not from a specialist appropriate for thyroid-related disorders like Graves’ Disease, further undermining its credibility against the CDP’s assessment.