The Supreme Court ruled that a company-designated physician’s assessment of a seafarer’s fitness to work generally prevails over that of a private physician, especially when the company doctor has closely monitored the seafarer’s condition over a prolonged period. This decision underscores the importance of following the established procedures in the POEA-SEC for resolving disputes regarding disability assessments. Practically, this means seafarers must adhere to the mandated process of seeking a third, jointly-appointed doctor if they disagree with the company physician’s findings to ensure their claims are properly considered.

Navigating Murky Waters: Whose Medical Opinion Holds Sway in Seafarer Disability Claims?

In this case, Eduardo C. Silagan sought disability benefits from his employer, Southfield Agencies, Inc. and Hyundai Merchant Maritime Co., Ltd., after sustaining a wrist injury while working as a Third Mate on a vessel. The central question was whether Silagan was entitled to compensation based on a disability assessment from his personal physician, which conflicted with the company-designated physician’s assessment that he was fit to work. The Supreme Court ultimately sided with the employer, clarifying the process and weight given to medical assessments in seafarer disability claims.

The case revolved around conflicting medical opinions regarding Silagan’s fitness to return to work. After his repatriation and subsequent treatment, the company-designated physician declared Silagan fit to resume his duties. Dissatisfied, Silagan consulted his own doctor who assessed him with a partial and permanent disability. Silagan argued that his personal physician’s assessment should be given more weight, entitling him to disability benefits under the Collective Bargaining Agreement (CBA). The company countered that the company-designated physician’s assessment was more reliable due to the continuous monitoring and treatment provided.

The legal framework governing this dispute is primarily found in Section 20(B) of the 2000 POEA-SEC (Philippine Overseas Employment Administration-Standard Employment Contract). This section outlines the liabilities of the employer when a seafarer suffers work-related injury or illness. Key provisions include the employer’s responsibility to provide medical attention until the seafarer is declared fit or the degree of disability is established by the company-designated physician. Furthermore, it stipulates that a seafarer is entitled to sickness allowance until declared fit to work or the degree of permanent disability has been assessed, not exceeding 120 days.

Notably, the POEA-SEC provides a mechanism for resolving disagreements in medical assessments:

“If a doctor appointed by the seafarer disagrees with the assessment, a third doctor may be agreed jointly between the Employer and the seafarer. The third doctor’s decision shall be final and binding on both parties.”

This provision underscores the importance of a mutually agreed-upon resolution process when medical opinions diverge.

The Supreme Court emphasized the significance of the company-designated physician’s assessment, citing their prolonged engagement with the seafarer’s case. The Court noted that Dr. Alegre, the company physician, had continuously monitored Silagan’s condition from the time of his repatriation through his surgeries and rehabilitation. This extensive oversight allowed Dr. Alegre to form a more reliable opinion compared to Dr. Almeda, Silagan’s personal physician, who only examined him once and based his assessment primarily on medical records. This perspective aligns with previous jurisprudence, as seen in Formerly INC Shipmanagement, Incorporated v. Rosales where the Court stated:

“The company-designated physician’s assessment should prevail over that of the private physician. The company-designated physician had thoroughly examined and treated Rosales… In contrast, the private physician only attended to Rosales once… the assessment of the company-designated physician is more credible for having been arrived at after months of medical attendance and diagnosis…”

Building on this principle, the Court also highlighted Silagan’s failure to comply with the mandatory procedure of seeking a third, jointly-appointed doctor to resolve the conflicting medical opinions. This step, outlined in Section 20(B)(3) of the 2000 POEA-SEC, is crucial when a seafarer disagrees with the company-designated physician’s assessment. The Court reiterated that this referral to a third doctor is not merely optional but a mandatory procedure. Failure to follow this procedure weakens the seafarer’s claim for disability benefits.

The absence of a third, impartial medical opinion was a significant factor in the Court’s decision. As the Court noted, the company can insist on its disability rating unless the seafarer expresses disagreement and requests referral to a third doctor. This requirement ensures that disputes are resolved through a neutral and binding assessment. Without this step, the company-designated physician’s assessment holds greater weight, further emphasizing the importance of adhering to established procedures.

The Supreme Court ultimately ruled against Silagan, affirming the Court of Appeals’ decision. The Court found that Silagan’s permanent disability was not established through substantial evidence, and that the appellate court did not err in reversing the NLRC ruling. While acknowledging the principle of liberality in favor of seafarers, the Court emphasized that when the evidence presented does not support compensability, the claim for disability benefits must fail. The decision reinforces the need for seafarers to follow proper procedures and present compelling evidence to support their claims for disability benefits.

FAQs

What was the key issue in this case?	The key issue was whether the seafarer was entitled to disability benefits based on his personal physician’s assessment, which conflicted with the company-designated physician’s assessment that he was fit to work. The Court ultimately decided whose medical opinion holds more weight.
What is the role of the company-designated physician?	The company-designated physician is responsible for assessing the seafarer’s medical condition, providing treatment, and determining their fitness to work. Their assessment is given significant weight, especially when they have monitored the seafarer’s condition over a prolonged period.
What happens if the seafarer disagrees with the company-designated physician?	If the seafarer disagrees with the company-designated physician’s assessment, they can request a third doctor jointly appointed by both the employer and the seafarer. The third doctor’s decision is final and binding on both parties.
Is the third doctor referral process mandatory?	Yes, the Supreme Court has emphasized that the referral to a third doctor is a mandatory procedure. Failure to follow this process can weaken the seafarer’s claim for disability benefits.
What is the POEA-SEC?	The POEA-SEC (Philippine Overseas Employment Administration-Standard Employment Contract) is a standard contract that governs the employment of Filipino seafarers on ocean-going vessels. It outlines the terms and conditions of employment, including compensation and benefits for injury or illness.
What is the significance of Section 20(B) of the POEA-SEC?	Section 20(B) of the POEA-SEC outlines the liabilities of the employer when a seafarer suffers work-related injury or illness. It specifies the employer’s responsibility to provide medical attention and compensation to the seafarer.
What is a Collective Bargaining Agreement (CBA)?	A Collective Bargaining Agreement (CBA) is a negotiated agreement between an employer and a labor union representing the employees. It typically covers terms and conditions of employment, such as wages, benefits, and working conditions.
How does this ruling affect seafarers seeking disability benefits?	This ruling reinforces the importance of following the proper procedures outlined in the POEA-SEC when seeking disability benefits. Seafarers must ensure they comply with the mandatory third doctor referral process if they disagree with the company-designated physician’s assessment.

In conclusion, this case highlights the critical role of the company-designated physician in assessing a seafarer’s fitness to work and underscores the importance of adhering to the procedural requirements outlined in the POEA-SEC. Seafarers seeking disability benefits should be aware of these requirements and take the necessary steps to protect their rights.

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: EDUARDO C. SILAGAN v. SOUTHFIELD AGENCIES, INC., G.R. No. 202808, August 24, 2016