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ELBURG SHIPMANAGEMENT PHILS. v. ERNESTO S. QUIOGUE

This case has been cited 3 times or more.

	GR No. 215471 2015-11-23	MARLOW NAVIGATION PHILIPPINES INC. v. BRAULIO A. OSIAS MENDOZA, J.
Finally, in Elburg Shipmanagement Phils., Inc. v. Quiogue, Jr.[30] (Elburg), it was affirmed that the Crystal Shipping doctrine was not binding because a seafarer's disability should not be simply determined by the number of days that he could not work. Nevertheless, the pronouncement in Carcedo was reiterated — that the determination of the fitness of a seafarer by the company-designated physician should be subject to the periods prescribed by law. Elburg provided a summation of periods when the company-designated physician must assess the seafarer, to wit: The company-designated physician must issue a final medical assessment on the seafarer's disability grading within a period of 120 days from the time the seafarer reported to him;
	GR No. 215313 2015-10-21	OLIMPIO O. OLIDANA v. JEBSENS MARITIME MENDOZA, J.
In the recent case of Elburg Shipmanagement Phils., Inc. v. Quiogue, Jr.,[23] the Court summarized the rules regarding the company-designated physician's duty to issue a final medical assessment on the seafarer's disability grading, as follows:1. The company-designated physician must issue a final medical assessment on the seafarer's disability grading within a period of 120 days from the time the seafarer reported to him;
	GR No. 212764 2015-09-09	HANSEATIC SHIPPING PHILIPPINES INC. v. ARLES BALLON MENDOZA, J.
Petitioners claim that the Vergara case modified the 120 days guideline by extending the period of treatment of the seafarer to 240 days. Their contention, however, is inaccurate. In the recent case of Elburg Shipmanagement Phils., Inc. v. Quiogue, Jr.[39] (Elburg), the Court synthesized the rules on the 120-day and 240-day extended periods for medical treatment on permanent and total disability as follows: The company-designated physician must issue a final medical assessment on the seafarer's disability grading within a period of 120 days from the time the seafarer reported to him;