Seafarers Can Claim Disability Benefits Even After Contract Completion

Philippine Transmarine Carriers Inc. v. Manzano, G.R. No. 210329, March 18, 2021

Imagine a seafarer who, after months of hard work on the high seas, returns home only to find that injuries sustained on the job have left them unable to continue their career. This was the reality for Clarito Manzano, whose case against his employers sheds light on the complexities of claiming disability benefits under Philippine law. This article delves into the Supreme Court’s decision in Philippine Transmarine Carriers Inc. v. Manzano, exploring the legal principles, the journey of the case, and what it means for seafarers and employers alike.

Legal Context: Navigating the Waters of Seafarer Disability Claims

In the Philippines, seafarers’ rights to disability benefits are governed by a combination of statutory provisions and contractual agreements. The key legal frameworks include Articles 191 to 193 of the Labor Code, which outline the disability benefits, and the Philippine Overseas Employment Administration-Standard Employment Contract (POEA-SEC), which is deemed incorporated into every seafarer’s employment contract.

The term “disability” in this context refers to a condition that prevents a seafarer from performing their usual work or any work they are suited for due to their training and experience. The POEA-SEC sets out specific rules for claiming disability benefits, including a requirement for seafarers to undergo a post-employment medical examination within three days of returning to the Philippines.

A crucial aspect of these regulations is the 240-day rule, which states that if a company-designated physician fails to issue a final assessment of the seafarer’s condition within 240 days from the initial examination, the seafarer’s disability is deemed permanent and total. This rule is pivotal in cases where the injury or illness manifests after the end of the employment contract.

Case Breakdown: The Voyage of Clarito Manzano

Clarito Manzano was hired as an Oiler by Philippine Transmarine Carriers Inc. and Marin Shipmanagement Limited for an eight-month contract aboard the Maersk Danang. During his tenure, Manzano suffered injuries to his knee and shoulder, which he claimed were due to accidents on board. Despite undergoing medical treatment, his condition did not improve, leading him to seek disability benefits upon his return to the Philippines.

Manzano’s journey through the legal system began with a Notice to Arbitrate filed with the National Conciliation and Mediation Board (NCMB), which ruled in his favor, awarding him disability benefits based on the Total Crew Cost Fleet Agreement (TCC CBA). The employers appealed to the Court of Appeals (CA), arguing that the TCC CBA did not apply as Manzano’s injuries were not proven to be from accidents.

The CA upheld the NCMB’s decision, emphasizing that Manzano’s injuries were linked to his work and that the company-designated physician had failed to issue a fitness certification within the 240-day period. The Supreme Court further clarified the legal landscape:

“Entitlement of seafarers to disability benefits is a matter governed, not only by medical findings, but by law and by contract.”

The Court also noted:

“The failure of the company-designated physician to render a final and definitive assessment of a seafarer’s condition within the 240-day extended period consequently transforms the seafarer’s temporary and total disability to permanent and total disability.”

The Supreme Court ultimately ruled that Manzano was entitled to permanent disability benefits under the POEA-SEC, even though he was repatriated for the end of his contract rather than for medical reasons.

Practical Implications: Charting a Course for Future Claims

This ruling has significant implications for seafarers and employers. Seafarers can now claim disability benefits even if their medical conditions manifest after their contract ends, provided they can prove a reasonable link to their work. Employers must be diligent in ensuring that company-designated physicians issue timely assessments to avoid automatic conversion to permanent disability status.

Key Lessons:

• Seafarers should document any work-related injuries or illnesses promptly and seek medical attention.
• Employers need to comply with the 240-day rule to avoid automatic disability status for seafarers.
• Both parties should be aware of the provisions of the POEA-SEC and any applicable CBAs.

Frequently Asked Questions

What qualifies as a work-related injury for seafarers?

An injury is considered work-related if it is reasonably linked to the seafarer’s work duties, even if it manifests after the contract ends.

How long does a seafarer have to claim disability benefits?

Seafarers must undergo a post-employment medical examination within three days of returning to the Philippines and should claim benefits within the 240-day period if no final assessment is issued.

Can a seafarer claim benefits if they were not medically repatriated?

Yes, as long as the injury or illness is work-related and the seafarer can prove it, they can claim benefits under the POEA-SEC.

What happens if the company-designated physician does not issue a final assessment within 240 days?

The seafarer’s disability is deemed permanent and total, entitling them to full disability benefits.

How are disability benefits calculated for seafarers?

Benefits are calculated based on the provisions of the POEA-SEC or any applicable CBA, with a maximum of US$60,000 for permanent total disability.

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