GR 173951; (April, 2012) (Digest)
G.R. No. 173951 ; April 16, 2012
DANIEL M. ISON, Petitioner, vs. CREWSERVE, INC., ANTONIO GALVEZ, Jr., and MARLOW NAVIGATION Co., Ltd., Respondents.
FACTS
Petitioner Daniel M. Ison was employed as a cook aboard M.V. Stadt Kiel. During his contract, he experienced chest pains and leg cramps. After medical tests abroad revealed abnormal findings, he was medically repatriated on June 24, 2000. Upon repatriation, respondents referred him to their company-designated physician at El Roi Diagnostic Center, where he was diagnosed with heart enlargement and hypertension. After two months of treatment at respondents’ expense, the physician declared him fit to return to work on August 25, 2000, with a note that his hypertension was controlled but required lifelong medication. Petitioner subsequently executed a release and quitclaim, acknowledging receipt of his sickness allowance.
Despite the fit-to-work assessment and quitclaim, petitioner filed a complaint for total and permanent disability benefits. He presented medical certificates from his personal physicians, Dr. Efren Vicaldo and Dr. Jocelyn Myra Caja, issued in 2001, which diagnosed him with hypertensive cardiovascular disease and declared him unfit for sea duty with various disability ratings. The Labor Arbiter dismissed the complaint, giving credence to the company physician’s assessment. The NLRC reversed, awarding disability benefits. The Court of Appeals then reinstated the Labor Arbiter’s dismissal.
ISSUE
Whether petitioner is entitled to total and permanent disability benefits despite the company-designated physician’s fit-to-work declaration and his execution of a quitclaim.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The ruling emphasized that while the POEA-SEC is construed liberally in favor of seafarers, the claimant must still substantiate the claim with credible evidence. The company-designated physician’s assessment, rendered after two months of treatment and based on continuous medical observation, carries greater weight than the opinions of petitioner’s personal doctors, which were based on isolated consultations conducted several months after the fit-to-work declaration.
The Court found no evidence that the company physician’s assessment was flawed or biased. Petitioner’s reliance on the subsequent medical opinions, without proof that his condition deteriorated after being declared fit, remained speculative. Furthermore, the quitclaim he voluntarily executed was deemed valid for lack of evidence that it was executed under fraud or duress; it was a reasonable settlement following the completion of medical treatment and the fit-to-work finding. Therefore, his claim for disability benefits, which hinged on surmises, could not be granted.