GR 223246; (June, 2019) (Digest)
G.R. No. 223246 , June 26, 2019
JAN FREDERICK PINEDA DE VERA, Petitioner, vs. UNITED PHILIPPINE LINES, INC. AND/OR HOLLAND AMERICA LINE WESTOUR, INC., AND DENNY RICARDO C. ESCOBAR, Respondents.
FACTS
Petitioner Jan Frederick Pineda De Vera was employed as a Bar Attendant by respondent United Philippine Lines, Inc. for its foreign principal. While on board, he experienced lower back pain and was medically repatriated. Upon arrival, he was treated by company-designated physicians. After a series of examinations and physical therapy sessions, the company doctors issued a final medical report on April 2, 2013, declaring him “fit to work.” On April 22, 2013, De Vera executed a Deed of Release and Quitclaim, receiving a sum of money in consideration for releasing respondents from all claims. Subsequently, on July 25, 2013, he consulted a private physician who declared him “unfit to work.”
De Vera filed a complaint for permanent and total disability benefits. The Labor Arbiter ruled in his favor, citing his inability to be re-employed. The National Labor Relations Commission (NLRC) reversed this, upholding the company doctors’ fit-to-work assessment and the validity of the quitclaim. The Court of Appeals affirmed the NLRC’s decision.
ISSUE
Whether the petitioner is entitled to permanent and total disability benefits.
RULING
No. The Supreme Court denied the petition and affirmed the rulings of the NLRC and the Court of Appeals. The legal logic centered on the primacy of the company-designated physician’s assessment and the validity of the executed quitclaim.
First, the company-designated physicians issued a definitive fit-to-work declaration within the 120/240-day treatment period framework. The assessment was based on a comprehensive evaluation, including specialist referrals and physical therapy, culminating in a final medical report stating De Vera completed handling tests without pain. A subsequent contrary opinion from a private doctor, obtained months after the fit-to-work declaration and the quitclaim, does not automatically overturn the company assessment, especially absent proof of bad faith or grave error by the company doctors.
Second, the Deed of Release and Quitclaim is valid and binding. The Court found it was executed voluntarily, for a reasonable consideration, and with a full understanding of its consequences. De Vera accepted final sickness allowance payments and executed the release after the fit-to-work finding but before seeking a private medical opinion. This constitutes a knowing waiver of any further claims. A quitclaim is a valid ground for denying monetary claims where, as here, there is no evidence it was executed under duress or fraud. Consequently, with a valid quitclaim and a lawful fit-to-work declaration, no basis exists for an award of disability benefits or attorney’s fees.