A Mere Finding that the Illness is Not Work-Related is Not Automatically a Valid Medical Assessment

2020 December 02

In Starocean Manning Philippines, Inc. v. Saturnino,1G.R. No. 252659, December 2, 2020. the Supreme Court stressed that sufficient basis must support the assessment of the company-designated physician:

Regardless of who the doctor is and his or her relation to the parties, the overriding consideration should be that the medical conclusions are based on (a) the symptoms and findings collated with medically acceptable diagnostic tools and methods, (b) reasonable professional inferences anchored on prevailing scientific findings expected to be known to the physician given his or her level of expertise, and (c) the submitted medical findings or synopsis, supported by plain English annotations that will allow the Labor Arbiter and the National Labor Relations Commission to make the proper evaluation.2Orient Hope Agencies, Inc. v. Jara, G.R. No. 204307, June 6, 2018.

If the company-designated physician failed to provide a final and definite medical assessment within the required periods, the seafarer’s condition shall be, by operation of law, characterized as total and permanent.3Ampo-on v. Reinier Pacific International Shipping, Inc., G.R. No. 240614, June 10, 2019.

Here, the employer failed to adduce evidence supporting the assessment that the seafarer’s illness was not work-related. For the Court, such unsupported finding of non-work-relatedness is an invalid medical assessment.

The seafarer was accordingly ruled to be entitled to total and permanent disability benefits by operation of law. The Court further applied Section 20(A)(7) of the 2010 POEA-SEC, which requires that such benefits be separate and distinct from, and be in addition to whatever benefits which the seafarer is entitled to under Philippine laws such as from the Social Security System, Overseas Workers Welfare Administration, Employees’ Compensation Commission, Philippine Health Insurance Corporation, and Home Development Mutual Fund.

Further reading:

  • Starocean Manning Philippines, Inc. v. Saturnino, G.R. No. 252659, December 2, 2020.