327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can a seafarer claim total and permanent disability benefits
if the company-designated physicians fail to issue a final and definitive
medical assessment within the prescribed 120/240-day period following medical
repatriation?
Kennedy R. Quines vs. United Philippine Lines, Inc. and/or
Shell International Trading and Shipping Co.
G.R. No. 248774 | May 12, 2021
Facts of the Case:
Kennedy R. Quines, a long-time seafarer working for United
Philippine Lines, Inc. (UPLI) and Shell International Trading and Shipping Co.
(Shell), began experiencing health issues during his deployment aboard a vessel
in July 2015. His duties involved strenuous physical tasks such as rigging
ladders, operating cranes, and carrying heavy loads. While performing these
duties, Quines began suffering from headaches, nausea, muscle cramps, and
stomach pain, leading to his medical repatriation due to hypertension.
Despite being declared "fit for work" after a
series of medical tests in the Philippines, Quines continued to experience
health problems. In March 2016, during a subsequent deployment, he suffered
from severe chest pains, dizziness, and high blood pressure. This led to
another medical repatriation. The company-designated physicians treated Quines
but did not issue a final medical assessment regarding his fitness for duty
within the 120/240-day window provided under Philippine law.
Feeling unwell and unable to return to work, Quines sought a
second opinion from an independent cardiologist, who diagnosed him with
Ischemic Heart Disease and declared him unfit for sea duty. Quines then sought
total and permanent disability benefits.
The Panel of Voluntary Arbitrators (PVA) ruled in Quines'
favor, awarding him total and permanent disability benefits. However, the Court
of Appeals reversed this decision, finding that Quines had not sufficiently
proven he suffered from a debilitating heart condition that rendered him
permanently unfit for sea duties. Quines elevated the matter to the Supreme
Court.
Primary Issue:
Is Kennedy R. Quines entitled to total and permanent
disability benefits due to the company-designated physicians’ failure to issue
a final and definitive medical assessment within the 120/240-day period?
Ruling of the Supreme Court:
The Supreme Court reversed the Court of Appeals' decision
and reinstated the ruling of the Panel of Voluntary Arbitrators. The Court held
that when a company-designated physician fails to issue a final and definitive
medical assessment within the required period of 120/240 days, the law deems
the seafarer to be totally and permanently disabled. The Court ruled that the
company-designated physicians did not issue a conclusive assessment on Quines'
fitness to work, as their reports were incomplete and inconclusive.
Furthermore, Quines had been continuously unemployed after
his medical repatriation, and his reliance on multiple maintenance medications
for hypertension—exceeding the allowable number for seafarers—made him unfit to
resume his duties.
Dispositive Portion:
The Supreme Court ordered United Philippine Lines, Inc. and
Shell International Trading and Shipping Co. to jointly and severally pay
Kennedy R. Quines the following:
- US$98,848.00
as total and permanent disability benefits or its peso equivalent at the
time of payment;
- 10%
attorney’s fees of the total monetary award; and
- 6% legal interest per annum on the total monetary award from the finality of the decision until full payment.
Should seafarers be automatically granted total and
permanent disability benefits if the company-designated physicians fail to
issue a conclusive medical assessment within the legal timeframe?
Key Doctrines:
- 120/240-Day
Rule
Failure by company-designated physicians to issue a final and definitive assessment within 120 or 240 days renders the seafarer totally and permanently disabled by operation of law. - Work-Related
Aggravation
Even if an illness is pre-existing, it is compensable if the strenuous nature of a seafarer's work has aggravated the condition. - Unfit
for Sea Duties
Under DOH Administrative Order No. 2007-0025, a seafarer requiring more than two maintenance medications for hypertension is considered unfit for sea duties, disqualifying them from further maritime employment.
4. Inconclusive
Medical Assessments
The Supreme Court emphasized that medical assessments from company-designated
physicians must be final, complete, and definitive to determine a seafarer's
fitness or unfitness for work. Vague or conditional findings, such as stating
that a seafarer "may" recover or "is not permanently
unfit," do not meet the required standard for a final medical report.
5.
Compensability of
Pre-existing Conditions
The Court reaffirmed the principle that pre-existing conditions do not exempt
employers from liability for disability benefits if the seafarer's work
aggravated the condition. Employers take employees as they find them, and they
assume the risk of an employee's weakened physical condition being exacerbated
by the nature of the work.
This
case falls under Labor Law
Looking for a reliable and affordable study companion for the 2025 Bar Exams? The Law Requisites PH offers expertly curated digital case digests designed specifically for bar examinees, law students, and legal professionals. With concise, organized content tailored to support your review and legal practice, you can now access these powerful tools for only ₱499. Start strengthening your preparation today by visiting https://beacons.ai/thelawrequisitesph. Your bar success begins with the right resources—get yours now!
CHAT WITH ME! (CLICK HERE)
🎓 In today’s
jurisprudence digest, we explore a landmark labor law decision from the Supreme
Court involving a medically repatriated seafarer whose right to total and
permanent disability benefits was put to the test due to a procedural lapse by
his employer's doctors.
This discussion will highlight essential doctrines,
especially the 120/240-day rule, aiding law students, reviewees, and
baristas in reinforcing their understanding of labor standards applicable
to seafarers.
📚 CASE DETAILS:
Date of Promulgation: May 12, 2021
Nature: Labor Law – Disability Benefits of
Seafarers
Brief Summary: Quines, a seafarer for 13 years, was
repatriated due to hypertension and chest pains. Despite multiple medications,
no definitive medical assessment was issued within the 240-day period. The Panel
of Voluntary Arbitrators ruled in his favor, but the Court of Appeals
reversed it. Ultimately, the Supreme Court reinstated the arbitral
decision, awarding him US$98,848 in permanent disability benefits.
🔍 Key Issue: Does
the failure of a company doctor to issue a final, definite assessment within
240 days entitle a seafarer to total and permanent disability benefits by
operation of law?
💬 Should workers lose
their rights due to an employer’s delay? Comment your thoughts!
🎯 10 MOST IMPORTANT
DOCTRINES
- Failure
to Issue Final Assessment = Permanent Disability
If a company-designated physician fails to provide a definitive medical assessment within 120/240 days, the disability is considered permanent and total. (G.R. No. 248774, May 12, 2021) - Fit
to Work Declaration Requires Clarity
Vague statements like "not permanently unfit" or “may improve” are not valid assessments. Finality is key. (Rollo p. 325–326) - Pre-Existing
Illness Does Not Bar Compensation
If work aggravated the condition, it is compensable regardless of whether the illness existed before employment. (More Maritime Agencies, cited in the decision) - Five
Maintenance Medicines = Unfit for Sea Duty
Under DOH AO No. 2007-0025, a seafarer taking more than two maintenance medicines is automatically deemed unfit for duty. (Rollo p. 182–183) - Company
Doctors' Inaction Weakens Defense
When doctors recommend further evaluation but the employer takes no action, the report loses credibility. (Rollo p. 190) - Psychiatric
Cause Must Be Proven
Claiming anxiety without actual psychiatric evaluation is insufficient to disprove disability. (Rollo p. 190–191) - Employment
History Matters
A long, unbroken employment record can help establish work-aggravated illness. Quines served from 2002 to 2015. (Rollo p. 181) - Continuous
Unemployment Implies Total Disability
Not being rehired or employed post-repatriation supports the claim of permanent disability. (Rollo p. 183–184) - PEME
is Not Conclusive on Health Status
Pre-Employment Medical Exam only screens seafarers; it does not rule out the development of work-aggravated conditions. (Rollo p. 182) - Legal
Interest Applies on Awards
Disability awards carry a 6% legal interest per annum from the finality of the decision until full payment. (Nacar v. Gallery Frames, cited)
⚖️ DISCLAIMER:
This video is made for educational purposes only. It
does not guarantee infallibility and was prepared using premium
artificial intelligence. Always verify with the latest jurisprudence and
legal counsel.
❓ FREQUENTLY ASKED QUESTIONS
(FAQs)
- Q:
What is the 120/240-day rule?
A: It refers to the period within which company-designated doctors must issue a final assessment on a seafarer’s condition. Beyond this, the law deems the disability permanent and total. - Q:
Can a seafarer still get benefits for pre-existing conditions?
A: Yes, if work aggravated the condition. - Q:
Is a PEME enough to prove a seafarer’s health?
A: No. A PEME is a basic screening tool and not a full diagnostic tool. - Q:
Can employers claim anxiety as a defense to deny claims?
A: Not without proper psychiatric evaluation and findings. - Q:
How much was awarded to Quines by the Supreme Court?
A: US$98,848, plus attorney’s fees and 6% legal interest.
🎬 Like, save to your
favorites, and subscribe to stay updated with more bar-relevant
jurisprudence and legal doctrines!
G.R. No. 248774 | Promulgated on May 12, 2021
📝 Nature of the Case:
Labor Law – Disability benefits, medical repatriation, 120/240-day rule,
seafarer's entitlement.
Case Summary:
Kennedy Quines, an Able Seaman, was repatriated due to
hypertension and chest pains. Despite undergoing treatment, the
company-designated physicians failed to issue a final and definite medical
assessment within 240 days. The Panel of Voluntary Arbitrators awarded him US$98,848
in total and permanent disability benefits. The Court of Appeals reversed
the award, but the Supreme Court reinstated it, emphasizing the
employer's failure to meet the legal obligation of timely assessment.
📌 The answer key
will be provided at the end of the video. Let’s test your understanding with
these easy-level HOTS (Higher Order Thinking Skills) questions!
🔍 QUIZZER – 10 EASY HOTS
MULTIPLE CHOICE QUESTIONS
1. What was the primary reason why the Supreme Court
ruled in favor of Kennedy Quines?
A. He was diagnosed with anxiety
B. His illness was unknown at the time of employment
C. No final medical assessment was issued within the
required period
D. He demanded excessive compensation
2. Under the ruling, what happens if a
company-designated doctor fails to issue a definitive assessment within the
legal period?
A. The employer may terminate the employee
B. The disability is deemed permanent and total
C. The employee must seek government assistance
D. The claim is dismissed outright
3. Why did the Court find the company doctors’
reports to be inconclusive?
A. They were unsigned
B. They used uncertain terms and lacked finality
C. They favored the employee
D. They were submitted late to the court
4. What was Kennedy Quines' profession?
A. Fisherman
B. Marine engineer
C. Cook
D. Able Seaman
5. What was a key indication that Quines was unfit
for sea duty based on health standards?
A. He had a prior criminal record
B. He failed a vision test
C. He took more than two maintenance medications
D. He was over the age limit
6. What critical step did the company fail to do
after recommending psychiatric evaluation?
A. Give additional leave
B. Assign a new vessel
C. Comply with the psychiatric referral
D. Inform the seafarer's family
7. What doctrine did the Supreme Court apply to rule
Quines permanently disabled by operation of law?
A. Finality of judgment
B. Continuity of service
C. 120/240-day rule
D. Force majeure doctrine
8. What was the amount awarded to Quines for total
and permanent disability?
A. US$10,000
B. US$50,000
C. US$98,848
D. US$120,000
9. What was the Court of Appeals’ reason for
reversing the arbitral tribunal’s decision?
A. Quines failed to apply for another job
B. No substantial evidence proved permanent unfitness
C. The arbitration panel was improperly constituted
D. Quines admitted to lying in his medical exam
10. What legal interest did the Supreme Court impose
on the monetary award?
A. None
B. 2% per annum
C. 6% per annum from finality until full payment
D. 12% per annum compounded monthly
No comments:
Post a Comment