GR 158883; (April, 2006) (Digest)
G.R. No. 158883 ; April 19, 2006
PHILIPPINE TRANSMARINE CARRIERS, INC., Petitioner, vs. JOHN MELCHOR A. LAURENTE, substituted by JUAN A. LAURENTE, JR. and NATIVIDAD A. AQUINO, Respondents.
FACTS
John Melchor A. Laurente was employed as a seafarer by petitioner Philippine Transmarine Carriers, Inc. under a 12-month contract commencing June 20, 1993. After three months onboard, he complained of dizziness and nausea and was repatriated on October 5, 1993. He was subsequently diagnosed with hypertension and chronic renal failure, classified as a Grade 1 disability. He underwent a kidney transplant in June 1994.
On March 30, 1995, Laurente filed a complaint for disability benefits. The Labor Arbiter awarded him US$50,000 based on the amended Philippine Overseas Employment Administration (POEA) Standard Employment Contract effective March 1, 1994, which increased the benefit from US$11,000. The National Labor Relations Commission (NLRC) initially reduced the award to US$11,000 but, upon reconsideration, reinstated the US$50,000 award. The Court of Appeals affirmed the NLRC. During the Supreme Court’s review, Laurente passed away and was substituted by his parents.
ISSUE
Whether the increased disability benefit of US$50,000 (and subsequently US$60,000) under the March 1994 POEA contract amendment applies to Laurente’s claim, notwithstanding his repatriation in October 1993.
RULING
Yes, the increased benefits apply. The Supreme Court affirmed the appellate court’s decision with modification, increasing the award to US$60,000. The legal logic rests on the application of favorable labor provisions and the specific terms of the employment contract. The contract incorporated the POEA Standard Employment Contract and its future amendments. Laurente’s disability was formally assessed and classified as Grade 1 on May 20, 1994, a date within his original contract period and after the effectivity of the beneficial amendment.
The Court rejected the petitioner’s argument that Laurente’s cause of action arose upon his repatriation in 1993. The determination of disability and the corresponding entitlement to benefits is reckoned from the date of the medical assessment, not the date of repatriation. Furthermore, the constitutional mandate to afford full protection to labor necessitates the application of corrective and favorable amendments like the increased disability rates. Since Laurente’s condition was an undisputed Grade 1 impediment, the contract schedule entitled him to 120% of the maximum rate, or US$60,000. The POEA-prescribed terms are deemed read into the employment contract and must be complied with in good faith.