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LACSON V. RCCL CREW [ G.R. No. 270817, January 27, 2025 ]

LACSON V. RCCL CREW [ G.R. No. 270817, January 27, 2025 ]
Posted by:PJP
Interactive Case Summary: Lacson v. RCCL Crew Management

SUPREME COURT - FIRST DIVISION

[ G.R. No. 270817, January 27, 2025 ]

CHARLONNE KEITH LACSON, PETITIONER, VS. RCCL CREW MANAGEMENT INC., ROYAL CARIBBEAN CRUISES LTD., AND GERARDO ANTONIO BORROMEO, RESPONDENTS.

Case Summary: Seafarer's Disability Benefits

  • This case clarifies the requirements for a valid medical assessment by a company-designated physician in a seafarer's disability claim. A seafarer, Charlonne Keith Lacson, was denied permanent disability benefits after the company doctor issued a report stating his work-related eczema was "resolved." The Supreme Court reversed the labor tribunals and the Court of Appeals, ruling that the medical report was not a final and definite assessment of his fitness to work or disability grade. Because no valid assessment was issued and communicated to the seafarer within the prescribed 120/240-day period, his disability became permanent and total by operation of law.
  • The Seafarer: Charlonne Keith Lacson was employed by RCCL as a Commis, with duties including food preparation and kitchen sanitation.
  • The Illness: While on board, Lacson developed painful skin rashes and blisters (diagnosed as Contact Dermatitis and Nummular Eczema) due to exposure to cleaning chemicals. He was medically repatriated on August 20, 2018.
  • Company Doctor's Assessment: The company-designated physician, Shiphealth, treated him until January 17, 2019 (151 days post-repatriation) and issued a "Final Report" stating his eczema was "resolved" and he was "cleared by Dermatology service."
  • Independent Assessment: Still suffering from rashes, Lacson consulted his own doctors in February 2019, who declared him "UNFIT for duty" and unfit to work in a kitchen. He then filed a claim for permanent and total disability benefits.
  • Labor Arbiter & NLRC Rulings: Both labor tribunals dismissed the complaint, ruling that the company doctor's assessment was final and binding because Lacson failed to initiate the third-doctor referral process.
  • Court of Appeals (CA) Ruling: The CA affirmed the labor tribunals, finding the company doctor's assessment to be valid, final, and definite.
  • Is a medical report stating an illness is "resolved" a valid, final, and definite assessment of a seafarer's fitness to work or disability grade?
  • Does a seafarer's disability become permanent and total by operation of law if a valid final assessment is not issued and furnished to them within the prescribed period?

The Supreme Court GRANTED the petition and REVERSED the CA decision.

  • Invalid Final Medical Report: The Court found that Shiphealth's Final Report was not a valid, final, and definite assessment. It failed to provide a categorical declaration of Lacson's fitness to work or a final disability grading. The statement "cleared by Dermatology service" was insufficient and ambiguous.
  • Disability by Operation of Law: Because the company-designated physician failed to issue a valid and definite assessment and furnish it to the seafarer within the 120/240-day period, Lacson's disability became permanent and total by operation of law.
  • Third-Doctor Rule Not Triggered: The failure to refer the matter to a third doctor was not fatal to the claim. Since the company doctor's assessment was invalid, there was nothing to properly contest, and the mandatory referral process was never triggered.
  • Valid Medical Assessment: A company-designated physician's final assessment must be complete, definite, and categorical. It must clearly state the seafarer's fitness to work or provide a final disability grading. A mere statement that an illness is "resolved" is insufficient.
  • 120/240-Day Rule: If the company doctor fails to issue a valid and definite medical assessment within 120 days (extendable to 240 days with sufficient justification), the seafarer's disability is deemed permanent and total by operation of law.
  • Duty to Inform: The employer has a correlative duty to fully and properly inform the seafarer of the company doctor's final assessment. Failure to do so violates due process and renders the assessment invalid.
  • Third-Doctor Rule: The mandatory referral to a third doctor only applies when there are two valid but conflicting assessments. If the company doctor's assessment is invalid or incomplete, the rule is not triggered.