G.R. No. 175795 ; June 22, 2015
Normilito R. Cagatin, Petitioner, vs. Magsaysay Maritime Corporation and C.S.C.S. International NV, Respondents.

FACTS

Petitioner Normilito R. Cagatin was employed by respondent Magsaysay Maritime Corporation as a Cabin Steward on board the vessel Costa Atlantica under a POEA-approved contract. After commencing work on April 24, 2001, he was reassigned to the Costa Tropicale on May 27, 2001, where he performed heavy cleaning and lifting tasks. In mid-July 2001, while performing his duties as Cabin Steward, he felt a “crackle” in his back followed by intense pain. After initial treatment on board, he was medically disembarked on July 28, 2001, and repatriated to the Philippines on August 1, 2001. He was referred to the company-designated physician, Dr. Nicomedes Cruz, who diagnosed him with “small central disc protrusion with annular fissure formation L5S1; disc annular bulge L4L5.” After treatment, Dr. Cruz declared petitioner “fit to work” on January 15, 2002. Almost seven months later, on August 6, 2002, petitioner consulted Dr. Enrique Collantes, Jr., who declared him unfit for sea duty with a Grade 8 (33.59%) disability rating. Petitioner filed a complaint for disability benefits. The Labor Arbiter ruled in his favor, but the NLRC reversed the decision, giving more weight to the company-designated physician’s fit-to-work assessment. The Court of Appeals affirmed the NLRC’s dismissal of the complaint.

ISSUE

Whether the Court of Appeals erred in affirming the NLRC’s decision which dismissed petitioner’s claim for disability benefits based on the company-designated physician’s fit-to-work declaration, despite a contrary finding by his private physician.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. The Court held that the findings of the company-designated physician, Dr. Cruz, are accorded greater weight over those of petitioner’s private physician, Dr. Collantes, in the absence of any showing of bad faith, malice, or fraud. The company-designated physician’s declaration that petitioner was “fit to work” on January 15, 2002, was based on medical examinations, including a normal EMG-NCV result, full range of motion, and improved lifting capacity. The Court emphasized that for an injury to be compensable, it must be work-related and existing during the term of the employment contract. Petitioner failed to substantiate his claim that his back injury was sustained during his employment, as the alleged incident was not documented in any accident report. Furthermore, the Court found that petitioner’s consultation with a private physician almost seven months after being declared fit to work was unjustifiably delayed and could not prevail over the timely and detailed assessment of the company-designated physician. Consequently, petitioner was not entitled to permanent disability benefits.