G.R. No. 161416 ; June 13, 2008
MAUNLAD TRANSPORT, INC., and/or NIPPON MERCHANT MARINE COMPANY, LTD., INC., petitioners, vs. FLAVIANO MANIGO, JR., respondent.

FACTS

Respondent Flaviano Manigo, Jr., a seafarer, was repatriated after suffering acute myocardial infarction. The company-designated physician, Dr. Nicomedes Cruz, examined him and eventually declared him “fit to work” in June 1999. Seven months later, Manigo filed a complaint for disability benefits. To support his claim, he presented a medical report from his personal physician, Dr. Efren Vicaldo, who diagnosed him with a Grade III disability, stating his illness prevented gainful employment. Given the conflicting medical opinions, the Labor Arbiter granted Manigo’s motion to be re-examined by a physician from the Employees’ Compensation Commission (ECC). Dr. Francisco Estacio of the ECC subsequently evaluated Manigo and issued a report recommending a permanent disability rating under Grade 3.
Petitioners Maunlad Transport, Inc. and Nippon Merchant Marine Company opposed the ECC examination and the admission of Dr. Estacio’s report. They argued that under the POEA Standard Employment Contract (POEA-SEC), the assessment of the company-designated physician regarding a seafarer’s fitness or disability is final and binding. They contended that the Labor Arbiter erred in seeking a third medical opinion.

ISSUE

Whether the Labor Arbiter is bound solely by the assessment of the company-designated physician and is precluded from allowing a re-examination by an ECC physician and admitting such a medical report in a claim for disability benefits.

RULING

The Supreme Court ruled against the petitioners and affirmed the actions of the Labor Arbiter and the Court of Appeals. The Court held that the POEA-SEC does not grant the company-designated physician’s assessment conclusive or final effect. While the contract designates the company physician to assess disability, this provision is intended to facilitate the prompt and expedient processing of claims, not to deprive the seafarer of due process or to make the physician’s finding immutable.
The legal logic is grounded on principles of equity and the constitutional mandate to afford full protection to labor. Conflicting medical assessments between the company doctor and the seafarer’s personal doctor create a factual issue that the labor tribunal must resolve. To hold the company physician’s opinion as absolute would be contrary to public policy and could lead to injustice. The Labor Arbiter, in the exercise of sound discretion, may order a re-examination by a neutral third physician to arrive at a just and equitable resolution. The Court emphasized that the POEA-SEC’s provisions must be construed fairly, reasonably, and in favor of the seafarer whose rights it seeks to protect. Therefore, the Labor Arbiter properly admitted the ECC physician’s report as part of the evidence to determine the merits of the disability claim.