G.R. No. 246125 , June 23, 2020
Pacific Ocean Manning, Inc., V. Ships UK Ltd., Southern Shipmanagement Co. S.A. and/or Engr. Edwin S. Solidum, Petitioners, vs. Ramon S. Langam, Respondent.

FACTS

Respondent Ramon S. Langam was hired as a chief cook. On January 2, 2017, hot cooking oil splashed into his right eye while on board. After initial treatment, he was medically repatriated. The company-designated physician, after a series of treatments and examinations, issued a final assessment on August 25, 2017, declaring a Grade 7 disability (loss of vision of one eye) under the POEA-SEC. Petitioners offered the corresponding partial disability benefit, which respondent refused.
Respondent instead consulted two private doctors, who diagnosed him with optic atrophy and declared him unfit for sea duty. Claiming permanent total disability, he filed a complaint before the Panel of Voluntary Arbitrators (PVA). The PVA ruled in his favor, awarding total disability benefits. The Court of Appeals affirmed this decision, giving weight to the opinions of respondent’s chosen physicians regarding his inability to work as a seafarer.

ISSUE

Whether respondent is entitled to permanent total disability benefits, or only to the partial disability benefits corresponding to the Grade 7 assessment issued by the company-designated physician.

RULING

The Supreme Court granted the petition and set aside the CA decision. Respondent is entitled only to Grade 7 partial permanent disability benefits. The legal logic centers on the procedural rules for claiming disability benefits and the primacy of the company-designated physician’s assessment when issued in accordance with law.
The Court emphasized that the company-designated physician issued a final, specific disability grading (Grade 7) within the 120/240-day period, as required. This assessment is deemed prima facie valid. Respondent’s recourse upon disagreement was to seek a referral to a third, jointly-agreed physician for a binding opinion, as stipulated in the POEA-SEC. He failed to do this. Instead, he unilaterally consulted private doctors whose assessments, based on limited consultations, cannot override the detailed and prolonged evaluation by the company doctor. The law designates the company physician for the initial assessment precisely to prevent self-serving claims.
Consequently, the Grade 7 assessment stands. The loss of vision in one eye, while serious, is explicitly classified as a partial, not total, disability under the POEA-SEC schedule. The award of attorney’s fees was also deleted for lack of evidence of bad faith on the part of the petitioners in processing the claim.