G.R. No. 221548 & 221561, October 03, 2018
Renerio M. Villas vs. C.F. Sharp Crew Management, Inc. / C.F. Sharp Crew Management, Inc. vs. Renerio M. Villas

FACTS

Seafarer Renerio M. Villas was hired by C.F. Sharp as a Second Engineer. On February 10, 2013, during a routine inspection, his right hand was crushed in a shipboard accident, resulting in the amputation of his right middle finger and injury to his ring finger. He was repatriated and treated by company-designated physicians. Despite months of treatment and rehabilitation, Villas continued to experience significant limitations, including severe weakness of grip and limited motion in his right hand. On June 6, 2013, a company-designated physician, Dr. Robert Chan, declared him fit to work. Contending he was still incapacitated, Villas sought a second opinion from an independent physician, Dr. Manuel Fidel M. Magtira, who assessed him with a Grade 9 disability (loss of opposition between thumb and fingertips). Villas then claimed total permanent disability benefits.
C.F. Sharp denied the claim, relying on Dr. Chan’s fit-to-work assessment and asserting that the injury only warranted a lower disability grading under the POEA contract. The dispute was elevated to the Panel of Voluntary Arbitrators (PVA), which ruled in favor of Villas, awarding him US$90,000 for total permanent disability under the applicable CBA. The Court of Appeals affirmed the PVA’s finding of total permanent disability but reduced the award to US$60,000, holding this was the correct amount under the CBA’s disability provisions. Both parties filed petitions before the Supreme Court.

ISSUE

The core issue was whether Villas was entitled to total permanent disability benefits and, if so, the correct amount payable under the governing Collective Bargaining Agreement.

RULING

The Supreme Court denied both petitions and affirmed the Court of Appeals’ decision. The Court upheld the finding of total permanent disability. It ruled that the company-designated physician’s fit-to-work declaration was issued prematurely on the 116th day of treatment, without a final and definitive assessment as required by law. The declaration was also contradicted by the seafarer’s persistent condition and the independent physician’s findings. The Court emphasized that disability is not a mere medical question but is determined by the seafarer’s incapacity to perform his customary work. Villas’s loss of grip strength and manual dexterity rendered him incapable of resuming his duties as an engineer, constituting total permanent disability.
Regarding the award, the Court clarified the applicable CBA provision. It distinguished between a “total loss” of function (compensable at US$90,000) and a “total loss” of a body part as listed in the schedule (compensable at US$60,000). The injury—loss of opposition between thumb and fingertips—was explicitly listed under “Hands” in the CBA schedule with a corresponding value of US$60,000. Therefore, the Court of Appeals correctly applied the scheduled amount of US$60,000, not the higher US$90,000 for unlisted total loss of function. The award was thus sustained.