G.R. No. 208089. September 28, 2016.
PHILIPPINE TRANSMARINE CARRIERS, INC., STEALTH MARITIME CORPORATION AND CARLOS SALINAS, PETITIONERS, VS. CASIANO F. SALADAS, JR., RESPONDENT.

FACTS

Respondent Casiano Saladas, Jr. was hired as Chief Cook under a nine-month POEA contract. He claimed that in March 2009, while on board, he fell when the vessel changed speed, hitting his chest, and later slipped from a ladder. He felt subsequent numbness and weakness but allegedly received no medical attention on board. He disembarked in Brisbane, Australia, on April 6, 2009, upon the completion of his contract. There, he consulted a doctor who conducted tests and prescribed medication, but Saladas did not receive the official medical results. Upon repatriation, his request for compensation was denied by petitioners. He later consulted a private physician in the Philippines, Dr. Efren Vicaldo, who diagnosed him with various conditions, including a rib fracture, and declared him unfit for sea duty.
The Labor Arbiter and the NLRC ruled in favor of Saladas, awarding total disability benefits. The Court of Appeals affirmed, holding that his injury was work-related and that his inability to work for over 120 days entitled him to benefits. The CA considered his disembarkation as a medical repatriation.

ISSUE

Did the Court of Appeals commit reversible error in affirming the NLRC’s award of total and permanent disability benefits to Saladas?

RULING

Yes, the Supreme Court reversed the CA. The legal logic centers on the failure to establish the fundamental element of work-relatedness and the proper procedure for claiming disability benefits under the POEA-SEC. The Court emphasized that in a petition for certiorari under Rule 45, it reviews whether the CA correctly determined the presence of grave abuse of discretion by the NLRC, not the merits of the case de novo.
The Court found that Saladas failed to substantiate his claim that his illnesses were work-related. He disembarked due to a finished contract, not for medical reasons. There was no official medical report from the company-designated physician upon his return, a critical procedural requirement. His subsequent consultation with a private doctor, without prior referral or a finding of the company doctor’s insufficiency, did not comply with the POEA-SEC rules. The medical certificate from Dr. Vicaldo was deemed insufficient to prove work-connection, as it did not establish that the rib fracture or other conditions were caused by the alleged onboard incidents. The petitioners’ denial of his claim, due to the absence of an endorsement from the foreign principal, was not a mere “bare denial” but highlighted the claimant’s failure to follow the prescribed procedure and present credible evidence linking his condition to his work. Consequently, the NLRC committed grave abuse of discretion in awarding benefits, and the CA erred in affirming this decision. The complaint was dismissed for lack of merit.