GR 226385; (August, 2019) (Digest)
G.R. No. 226385 . August 19, 2019
CELSO S. MANGUBAT, JR., PETITIONER, VS. DALISAY SHIPPING CORPORATION, WEALTH SHIPPING LIMITED AND DANNY DADILA, RESPONDENTS.
FACTS
Petitioner Celso S. Mangubat, Jr., employed as an oiler, suffered a work-related injury on February 28, 2014, fracturing his right leg. He was repatriated and treated by the company-designated physician. After surgery and rehabilitation, the physician noted on August 8, 2014, that petitioner was ambulatory without difficulty, had no pain on weight-bearing, and declared him “fit to work.” Petitioner later consulted his own doctor at San Geronimo General Hospital, which issued a certificate dated September 23, 2014, stating he needed further physical therapy for about a year due to muscle atrophy. During conciliation proceedings, petitioner moved for referral to a third doctor, but the conciliator-mediator denied the request, prompting petitioner to file a complaint for disability benefits.
The Labor Arbiter dismissed the complaint, finding the company-designated physician’s detailed assessment credible and noting petitioner’s own doctor failed to specify treatments or tests conducted. The NLRC affirmed but awarded USD 7,000 as financial assistance. The Court of Appeals dismissed petitioner’s certiorari petition, upholding the factual findings of the labor tribunals.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of petitioner’s claim for disability benefits.
RULING
The Supreme Court denied the petition, affirming the CA’s resolutions. The legal logic centers on the validity and definitiveness of medical assessments under the POEA-SEC. The company-designated physician issued a final and definite assessment declaring petitioner “fit to work” after months of detailed treatment and monitoring. This assessment is presumed valid under jurisprudence. In contrast, the medical certificate from petitioner’s own doctor was deemed invalid and indefinite as it merely stated he was “treated” and needed further therapy without providing a conclusive disability grading or detailed medical basis. An assessment must be definite and final; an inconclusive one does not trigger the obligation for the employer to respond to a request for a third doctor.
Since petitioner’s own doctor did not issue a valid assessment, the company-designated physician’s evaluation stands. Petitioner’s request for a third-doctor referral during conciliation was correctly not compelled, as the procedural mechanism for referral presupposes a conflict between two valid assessments. The labor tribunals’ factual findings, supported by substantial evidence, were correctly accorded finality. Thus, petitioner failed to prove entitlement to permanent total disability benefits.