G.R. No. 223730 & G.R. No. 223782. OCTOBER 4, 2017. DOHLE PHILMAN MANNING AGENCY, INC., DOHLE (IOM) LIMITED and/or CAPT. MANOLO T. GACUTAN, Petitioners, vs. JULIUS REY QUINAL DOBLE, Respondent. (Consolidated Cases)
FACTS

Julius Rey Quinal Doble, an Ordinary Seaman, was employed by DOHLE (IOM) Ltd. through its local agent. During his contract, he reported two injuries: a twisted right foot in December 2012 and a hand injury in March 2013. He was eventually repatriated for medical reasons on April 11, 2013. The company-designated physician diagnosed him with Right Ankle Sprain, Bilateral Carpal Tunnel Syndrome, and an Osteochondral Defect in his right knee. After surgery and therapy, the physician issued an interim disability assessment. Ultimately, on November 8, 2013, within the 240-day period, the physician issued a final medical report declaring Doble fit to work.
Dissatisfied, Doble consulted his personal physician, Dr. Manuel Fidel Magtira, who declared him permanently unfit for sea duty. Doble thus filed a complaint for permanent total disability benefits. The Labor Arbiter and the National Labor Relations Commission (NLRC) ruled in his favor, a decision affirmed by the Court of Appeals (CA), which modified the award’s basis to the POEA-SEC.

ISSUE

Whether or not Julius Rey Quinal Doble is entitled to permanent total disability benefits.

RULING

No. The Supreme Court reversed the CA and dismissed Doble’s complaint. The legal logic centers on the binding nature of the company-designated physician’s assessment when issued in accordance with the POEA-SEC. The Court emphasized that while seafarers are protected, they are also bound by the contract’s terms. The company physician issued a final “fit to work” declaration on November 8, 2013, which was within the 240-day period allowed for assessment. This declaration became final and binding because Doble failed to validly contest it by referring the dispute to a third-doctor, as mandated by the POEA-SEC and established jurisprudence.
The Court rejected Doble’s reliance on his personal doctor’s contrary opinion. The law requires that in case of disagreement between the company doctor and the seafarer’s doctor, the conflicting assessments must be referred to a third, mutually agreed-upon physician whose decision shall be final. Doble’s unilateral act of securing a second opinion without initiating this referral process rendered the company doctor’s fit-to-work assessment conclusive. Consequently, Doble was not suffering from a permanent total disability as defined by law and contract, and was thus not entitled to disability benefits. The grant of the petitions by the employers was proper.