G.R. No. 186289; June 29, 2010
Oriental Shipmanagement Co., Inc., Petitioner, vs. Romy B. Bastol, Respondent.

FACTS

Petitioner Oriental Shipmanagement Co., Inc. (OSCI) deployed respondent Romy B. Bastol as a bosun in December 1995. On February 17, 1997, while on board, Bastol suffered a heart attack (anterior myocardial infarction) and was subsequently repatriated. Upon arrival, he was examined by a company-designated physician, Dr. Robert D. Lim, and underwent treatment until at least October 1997. Unsatisfied, Bastol sought a second opinion from Dr. Efren Vicaldo of the Philippine Heart Center, who assessed him with a Grade 1 (120%) disability. Bastol’s claim for disability benefits was denied by OSCI, which argued he failed to complete treatment with the company-designated physician, who alone could assess disability under the POEA contract.
The Labor Arbiter awarded Bastol full disability benefits, but the NLRC vacated this decision and remanded the case for further proceedings, ordering Bastol to personally appear and for both doctors to testify. The Court of Appeals reversed the NLRC and reinstated the Labor Arbiter’s award. OSCI elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

Whether the Court of Appeals erred in reinstating the Labor Arbiter’s decision awarding total and permanent disability benefits to Bastol without the case being remanded for the reception of additional evidence, specifically the testimonies of the doctors and Bastol’s personal appearance.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The legal logic is anchored on the nature of labor proceedings and the sufficiency of evidence on record. The NLRC’s order for remand was improper. Labor proceedings are not bound by strict technical rules of procedure; decisions can be based on position papers and supporting documents without a formal trial. The records contained substantial evidence—medical reports, the employment contract, and communications—which allowed for a fair determination of the claim.
Crucially, the company-designated physician, Dr. Lim, failed to issue a final disability assessment within the 120-day period mandated by the POEA contract, despite Bastol undergoing treatment. This failure rendered Dr. Vicaldo’s independent assessment credible and sufficient to establish permanent total disability. A remand to compel Bastol’s appearance and the doctors’ testimonies would have been a mere formality and would have further delayed the resolution of a simple claim for disability benefits, contrary to the constitutional mandate for speedy labor justice. The Labor Arbiter and the Court of Appeals correctly adjudicated the case based on the documentary evidence presented.