In maritime law, when a seafarer claims disability benefits, the assessment of the company-designated physician generally takes precedence, provided it is well-substantiated and credible. This case emphasizes that while a seafarer can seek a second opinion from a private physician, the company doctor’s assessment, when thorough and based on objective findings, often prevails. The Supreme Court upheld the Court of Appeals’ decision, favoring the company-designated physician’s disability grading over that of the seafarer’s personal doctor, underscoring the importance of the basis and reliability of medical assessments in disability claims. The ruling confirms the limited disability benefits awarded to the seafarer based on the company doctor’s evaluation.

Whose Diagnosis Prevails? A Seafarer’s Battle for Fair Disability Compensation

This case revolves around Prudencio Caranto, a seafarer who worked as a Chief Steward/Cook for Bergesen D.Y. Phils. and Bergesen D.Y. ASA. Caranto sought disability benefits after being diagnosed with diabetes mellitus and hypertension during his employment. The central legal question is whether the medical assessment of the company-designated physician or that of the seafarer’s private physician should prevail in determining the extent of disability and corresponding compensation.

Caranto’s medical journey began with a pre-employment medical examination (PEME) that noted his diabetes. While at sea, he experienced severe symptoms and was diagnosed with diabetes and hypertension, leading to his repatriation. Upon returning to the Philippines, he was examined by Dr. Cruz, the company-designated physician, who initially declared him fit to work after a few months. Dissatisfied, Caranto sought a second opinion through his counsel, leading to an assessment by Dr. Alegre, who found him unfit for work and assigned a disability grade of 12. Subsequently, a private physician, Dr. Vicaldo, assessed Caranto with a higher disability grade of V (58.96%), leading to conflicting medical opinions and the core of the legal dispute. The conflicting assessments necessitated a resolution on whose medical opinion should hold greater weight.

The Labor Arbiter (LA) initially favored Dr. Vicaldo’s assessment, awarding Caranto US$60,000.00 in disability benefits, aligning with the Collective Bargaining Agreement (CBA). However, the National Labor Relations Commission (NLRC) affirmed the LA’s decision, further solidifying the award in Caranto’s favor. Displeased, the respondents elevated the case to the Court of Appeals (CA), which reversed the NLRC’s decision, giving more weight to Dr. Alegre’s assessment and awarding Caranto a lesser amount of US$5,225.00, based on a Grade 12 disability. The CA’s decision hinged on the substantiation and reliability of the medical findings.

The Supreme Court, in its analysis, reiterated the importance of the company-designated physician’s role in assessing a seafarer’s disability. Citing established jurisprudence, the Court acknowledged that while the company doctor’s assessment is not automatically binding, it carries significant weight. The Court noted that a seafarer has the right to seek a second opinion, but the assessment of the company-designated physician, if well-reasoned and supported by objective findings, should be given preference. This principle is rooted in the employment contract and the POEA Standard Employment Contract.

The Court emphasized the significance of the medical basis for disability assessments. In this case, Dr. Alegre’s findings were based on laboratory examinations, providing a more objective foundation for her assessment. On the other hand, Dr. Vicaldo’s assessment lacked such concrete evidence, relying more on general impressions and potential long-term complications. The Court agreed with the CA’s rationale, stating that “the determination of whose medical findings, including disability assessment, should be given more weight would depend on the length of time the patient was under treatment and supervision, results of laboratory procedures used as basis for diagnosis and recommendation, and detailed knowledge of the patient’s case reflected in the medical certificate itself.” This highlights the need for a thorough and evidence-based medical assessment.

Moreover, the Supreme Court addressed Caranto’s claim for a higher disability benefit under the CBA, which provided for US$60,000.00 for cases of permanent medical unfitness. The Court clarified that this provision was not applicable because Dr. Alegre did not certify Caranto as permanently unfit for further sea service. Dr. Alegre’s report indicated that Caranto’s condition could be managed with proper diet, exercise, and medication, implying that he was not permanently incapacitated. This interpretation reinforces the importance of adhering to the specific terms and conditions outlined in the employment contract and CBA.

The Court also distinguished this case from Crystal Shipping Inc. v. Natividad, where the seafarer was deemed permanently and totally disabled due to an extended period of medical treatment. In Caranto’s case, he was declared fit to work within the 120-day period from his sign-off, which did not qualify as a permanent total disability. The Supreme Court’s decision underscores the significance of the medical assessment made by the company-designated physician, especially when supported by substantial evidence and objective findings. It provides clarity on the hierarchy of medical opinions in seafarer disability claims, reinforcing the employer’s right to rely on their designated medical professionals.

The ruling also highlights the importance of seafarers complying with medical advice and treatment plans. The Court noted that the difference in assessments between Dr. Cruz and Dr. Alegre was attributed to Caranto’s non-compliance with medication. This underscores the seafarer’s responsibility to adhere to medical instructions, as non-compliance can affect their disability assessment and potential benefits. This decision aligns with existing jurisprudence, emphasizing the importance of the company-designated physician’s assessment in disability claims while recognizing the seafarer’s right to seek a second opinion.

FAQs

What was the key issue in this case?	The central issue was determining whether the medical assessment of the company-designated physician or the seafarer’s private physician should prevail in assessing disability and awarding compensation.
Who is the company-designated physician?	The company-designated physician is a doctor appointed by the employer to assess the seafarer’s medical condition, determine disability, and provide medical reports as required by the POEA Standard Employment Contract.
What is the POEA Standard Employment Contract?	The POEA Standard Employment Contract sets the terms and conditions of employment for Filipino seafarers working on foreign vessels, including provisions for disability compensation and medical benefits.
What disability grade did the company-designated physician assign to Caranto?	Dr. Alegre, the company-designated physician, assigned Caranto a disability grade of 12, which corresponds to a slight residual disorder of the intra-thoracic and intra-abdominal organs.
What was the basis for the Court’s decision to favor the company-designated physician’s assessment?	The Court favored the company-designated physician’s assessment because it was based on objective laboratory results and a more detailed medical history compared to the private physician’s assessment.
What is the significance of the 120-day period in disability claims?	The 120-day period refers to the time within which the company-designated physician must assess the seafarer’s disability; if the assessment extends beyond this period, it may lead to a finding of permanent total disability.
What did the Collective Bargaining Agreement (CBA) provide in this case?	The CBA provided for a higher disability benefit of US$60,000.00 in cases of permanent medical unfitness, but this was not applied because Caranto was not certified as permanently unfit for sea service by the company doctor.
What is the seafarer’s responsibility regarding medical treatment?	The seafarer has a responsibility to comply with the prescribed medical treatment and medication, as non-compliance can affect the assessment of their disability and the benefits they may receive.
Can a seafarer seek a second medical opinion?	Yes, a seafarer has the right to seek a second medical opinion from a doctor of their choice, but the company-designated physician’s assessment still carries significant weight, especially when well-substantiated.

The Supreme Court’s decision in this case clarifies the weight given to medical assessments in seafarer disability claims, reinforcing the importance of the company-designated physician’s role while acknowledging the seafarer’s right to seek a second opinion. This decision provides guidance for future cases involving conflicting medical opinions and highlights the need for seafarers to comply with medical advice and treatment plans to support their claims.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Prudencio Caranto v. Bergesen D.Y. Phils., G.R. No. 170706, August 26, 2015