When an Interim Medical Assessment Is Not Enough: Seafarer Wins Full Disability Benefits

The Supreme Court recently reminded employers that an interim medical assessment cannot be treated as final to cut off a seafarer's treatment and disability benefits. In Hisanza v. Bright Maritime Corporation (G.R. No. 265454, April 7, 2025), the Court ruled that when a company-designated physician issues only a tentative rating and stops treatment before the reglementary period lapses, the seafarer is deemed totally and permanently disabled by operation of law.

The Facts

Adan De Guzman Hisanza was a seafarer hired by Bright Maritime Corporation for deployment on vessels of its principal, Navios Shipmanagement, Inc. In May 2017, while working as an able-bodied seaman, he felt severe back pain that did not improve with medication. He was repatriated and underwent treatment from June to December 2017.

On December 5, 2017—the 190th day of his treatment—the company physician issued a "10th Progress Report" giving an interim disability grade of 11 for slight rigidity or one-third loss of motion in the trunk. The report also prescribed continued medication and physical therapy. Despite this, Bright informed Hisanza it would no longer shoulder further treatments.

Hisanza sought a second opinion from an orthopedic specialist, who rated his disability at grade 3 and declared him unfit for seafaring work. When the parties could not agree, Hisanza filed a complaint for permanent disability benefits. The Labor Arbiter and the NLRC awarded him only grade 11 benefits (USD 7,465), and the Court of Appeals affirmed. The Supreme Court reversed.

The Issue

The central question was whether the company physician's December 2017 report was a valid final assessment that could justify stopping treatment and limiting disability benefits.

The Ruling

The Court held that the December 2017 report was not a final, conclusive, and definite medical assessment. It was labeled an "interim" rating, issued while treatment was ongoing, and it still required continued medication and physical therapy. Under the POEA-SEC, a final assessment must clearly state whether the seafarer is fit to work or the exact disability rating, without any further condition or treatment.

Because the assessment was tentative and the company stopped treatment prematurely, the employer failed to comply with its obligations. The Court applied the rule that failure to issue a definitive assessment within the reglementary treatment period (120 days, extendible by another 120 days) gives rise to a conclusive presumption that the seafarer is totally and permanently disabled.

The Court also noted that the seafarer's belated raising of the issue before the NLRC was not fatal, since labor proceedings are not strictly bound by technical rules of procedure. The award: USD 60,000 in permanent disability benefits (the grade 1 rate under the POEA-SEC schedule), plus 10% attorney's fees and 6% interest per annum from finality of the decision.

Practical Takeaways

• Interim is not final. A company physician's assessment labeled "interim," "progress report," or "in the meantime" does not satisfy the POEA-SEC requirement of a final, definite, and conclusive declaration.
• Treatment cannot be cut off early. If the assessment still recommends further medication or therapy, the employer cannot use it to stop shouldering treatment and then rely on it to limit benefits.
• The 240-day rule matters. If no valid final assessment is issued within the reglementary period (120 days, extendible to 240), the seafarer is presumed totally and permanently disabled by operation of law.
• Third-doctor referral becomes moot. When the company assessment is invalid for being interim, the question of whether a third-doctor referral was required no longer determines the outcome.
• For seafarers: Keep all medical reports and progress notes. If the company physician issues only a tentative rating, document that treatment was ongoing and that the company stopped payment prematurely.

This article is general information and not legal advice. For your specific situation, consult a lawyer or ask ASG Legal AI.