Law Labor Digest: PHILIPPINES TRANSMARINE CARRIERS, INC. v. NATIONAL LABOR RELATIONS COMMISSION et al (G.R. No. 123891, Feb. 28, 2001)

Law Labor Digest: PHILIPPINES TRANSMARINE CARRIERS, INC. v. NATIONAL LABOR RELATIONS COMMISSION et al 

(G.R. No. 123891, Feb. 28, 2001)

FACTS:

Private respondent, Carlos Nietes filed a complaint against Philippine Transmarine Carriers Inc. (PTC) for payment of disability benefit, sickness wages, refund of medical expenses and attorney’s fees. POEA Adjudication Office issued its decision in favor of the private respondent awarding disability benefit.

Petitioner admits that private respondent suffered illness which rendered him unfit for work. However, it points out that private respondent did not submit proof of the extent of his disability as required by Section C (4) [b] and [c] of the POEA Standard Contract for Seamen. Without this proof, petitioner argues that the NLRC gravely abused its discretion when it affirmed the findings of the POEA Adjudication Office.

ISSUE:

Whether the NLRC gravely abused its discretion in affirming with modification, the judgment of the POEA Adjudication Office.

HELD: 

NO. Strict rules of evidence are not applicable in claims for compensation. 

In NFD International Manning Agents, Inc. vs. NLRC, 269 SCRA 486, 494 (1997), we said:

Strict rules of evidence, it must be remembered, are not applicable in claims for compensation and disability benefits. Private respondent having substantially established the causative circumstances leading to his permanent total disability to have transpired during his employment, we find the NLRC to have acted in the exercise of its sound discretion in awarding permanent total disability benefits to private respondent. Probability and not the ultimate degree of certainty is the test of proof in compensation proceedings.

The POEA Standard Employment Contract for Seamen is designed primarily for the protection and benefit of Filipino seamen in the pursuit of their employment on board ocean-going vessels. Its provisions must, therefore, be construed and applied fairly, reasonably and liberally in their favor. Only then can its beneficent provisions be fully carried into effect.

Petition is DISMISSED.