In Henry Dionio v. Trans-Global Maritime Agency, Inc., the Supreme Court addressed the weight given to a company-designated physician’s assessment in seafarer disability claims. The Court ruled that while the company doctor’s opinion is significant, it’s not conclusive, especially when evidence suggests bias or a failure to fully consider the seafarer’s condition. This decision highlights the importance of protecting seafarers’ rights to fair disability compensation, even when they don’t strictly follow the third-doctor referral process. The ruling ensures a balanced approach, prioritizing both the medical expert’s assessment and the seafarer’s well-being.

When ‘Guarded’ Prognosis Trumps Disability Grade: A Seafarer’s Fight for Fair Compensation

Henry Dionio, a Bosun, experienced a health crisis at sea, leading to a diagnosis of Bilateral Cerebellar Infarct. Upon repatriation, the company-designated physician assigned a Grade 10 disability but cautioned against returning to sea due to the risk of another cerebrovascular event. Dionio sought a second opinion confirming his unfitness for sea duty. The central legal question was whether the company doctor’s disability grade should prevail, despite the doctor’s own reservations about Dionio’s ability to safely return to work.

The legal framework for seafarer disability claims is primarily governed by the POEA-SEC. Section 20(A) of the POEA-SEC outlines the procedure for medical evaluations, including the role of the company-designated physician and the process for seeking a second opinion. This section also addresses the resolution of conflicting medical assessments through a third, mutually agreed-upon doctor. The case hinges on how to interpret and apply these provisions, particularly when the company doctor’s assessment contains seemingly contradictory statements. This is the core of the legal challenge in this case.

The Supreme Court emphasized that while the company-designated physician’s assessment holds significant weight, it’s not the final word, especially if there’s evidence of bias or the assessment isn’t fully supported by medical findings. The Court referenced CF Sharp Crew Management, Inc. v. Castillo, stating:

Based on jurisprudence, the findings of the company-designated physician prevail in cases where the seafarer did not observe the third­ doctor referral provision in the POEA-SEC. However, if the findings of the company-designated physician are clearly biased in favor of the employer, then courts may give greater weight to the findings of the seafarer’s personal physician. Clear bias on the part of the company­ designated physician may be shown if there is no scientific relation between the diagnosis and the symptoms felt by the seafarer, or if the final assessment of the company-designated physician is not supported by the medical records of the seafarer.

Building on this principle, the Court acknowledged Dionio’s failure to formally initiate the third-doctor referral process. However, the Court refused to blindly accept the company doctor’s Grade 10 disability assessment. The court noted the inherent contradiction in the company doctor’s report, which, while assigning a disability grade, also explicitly warned against Dionio’s return to sea due to the high risk of another stroke. This inconsistency raised doubts about the objectivity and completeness of the assessment.

The Court’s decision aligns with the State’s policy of providing maximum aid and protection to labor. As the court noted, “the notion of disability is intimately related to the worker’s capacity to earn, and what is compensated is not his injury or illness but his inability to work resulting in the impairment of his earning capacity.” The court emphasized that disability should be construed more on the loss of earning capacity than on medical significance. The key question is whether the seafarer can return to his previous work, or similar work, without endangering his health.

Furthermore, the Supreme Court highlighted that the Labor Code concept of disability applies to Filipino seafarers. This means that a seafarer is considered totally disabled if they are unable to earn wages in the same kind of work or work of similar nature that he or she was trained for, or accustomed to perform, or any kind of work which a person of his or her mentality and attainments could do. Permanent disability, on the other hand, exists when the worker is unable to perform his or her job for more than 120 or 240 days, regardless of whether or not he loses the use of any part of his or her body. In Dionio’s case, the Court considered the company doctor’s warning against returning to sea duty, coupled with the extended period of his inability to work, as sufficient grounds for a finding of permanent and total disability.

The Court ultimately ruled in favor of Dionio, reinstating the NLRC decision that awarded him total and permanent disability benefits. This ruling underscores that a seafarer’s actual capacity to work is a crucial factor in determining disability, even if the company doctor assigns a lower disability grade. While the procedure for seeking a third doctor is important, it shouldn’t be used to deny rightful compensation when the evidence clearly demonstrates the seafarer’s inability to return to their profession. This decision sets a precedent for future cases, emphasizing a more holistic approach to assessing seafarer disability claims.

FAQs

What was the key issue in this case?	The key issue was whether a company-designated physician’s disability grading prevails even when the physician advises against the seafarer’s return to sea duty due to health risks.
What is the role of the company-designated physician?	The company-designated physician has the initial responsibility to assess the seafarer’s medical condition and provide a disability assessment, which initially informs the seafarer’s entitlement to benefits.
What if the seafarer disagrees with the company doctor’s assessment?	The seafarer can seek a second opinion from a doctor of their choice. If the opinions differ, the POEA-SEC provides for a third, mutually agreed-upon doctor to provide a final binding assessment.
Is the third-doctor referral mandatory?	While the third-doctor referral is generally mandatory, the court can consider other evidence if the company doctor’s findings are biased or unsupported by medical records.
What is ‘permanent total disability’ in this context?	Permanent total disability means the seafarer is unable to earn wages in the same kind of work or work of similar nature they were trained for.
What was the Court’s basis for ruling in favor of the seafarer?	The Court considered the company doctor’s warning against returning to sea, combined with the seafarer’s prolonged inability to work, as evidence of permanent total disability.
What is the significance of the POEA-SEC in these cases?	The POEA-SEC provides the standard terms and conditions of employment for Filipino seafarers, including provisions for medical care and disability compensation.
How does this ruling impact future seafarer disability claims?	This ruling emphasizes that a seafarer’s actual capacity to work is a key factor, and courts can look beyond the company doctor’s assessment when the evidence warrants it.

The Dionisio decision provides important clarification on the process for assessing seafarer disability claims. It serves as a reminder that while the company-designated physician’s opinion is important, it is not the only factor to be considered. The seafarer’s actual condition, their ability to return to work, and any potential biases in the medical assessments must also be taken into account to ensure a just outcome.

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: Henry Dionio v. Trans-Global Maritime Agency, Inc., G.R. No. 217362, November 19, 2018