Dangue v. Franklin Baker Company
REITERATIONFacts
The Antecedents: Petitioner Cayetano Dangue, an employee of respondent Franklin Baker Company of the Philippines, sustained an injury to his right eye on July 17, 1954, while cleaning his kaingin. He consulted the company physician, who found nothing serious. On July 20, 1954, while working as a shelter (shelling coconuts), a flying speck of coconut shell struck his right eye, causing unbearable pain and blurring of vision. He was advised to take a leave of absence on July 21, 1954, which was extended until November 10, 1954. During this period, he underwent three operations, resulting in a 16.4% loss of vision, causing temporary total disability and permanent partial disability. He was not paid compensation for this period. Procedural History: On September 6, 1954, petitioner filed a complaint for compensation. The Hearing Officer ordered the company to pay P460.77. The Workmen's Compensation Commission (WCC) reviewed the decision and, on March 12, 1959, dismissed the claim. A motion for reconsideration was denied by the WCC en banc on June 23, 1959. The Petition: Petitioner sought review of the WCC's decision, claiming the Commission erred in dismissing his claim for compensation and in absolving the company from liability.
Issue(s)
Whether the respondent Commission erred in dismissing petitioner's claim for compensation. Whether the respondent Commission erred in absolving respondent company from liability despite its non-controversion of petitioner's claim and admission of his injury in the performance of his regular work.
Ruling
The appealed decision and resolution of the respondent Commission are set aside. Respondent Franklin Baker Co. is ordered to pay petitioner the amount of P460.77 as compensation, and P5.00 to the respondent Commission.
Ratio Decidendi
On the issue of dismissing the claim for compensation: The Court agreed with the petitioner. It was noted that the company physician allowed the petitioner to work after the first incident on July 17, 1954, indicating it was not serious. However, the second accident on July 20, 1954, while petitioner was performing his work for the company, was serious enough to warrant a leave of absence and subsequent operations. The Court held that even if the initial injury occurred outside of employment, it became worse or was aggravated by the accident that happened during the course of his employment. Therefore, the petitioner is entitled to compensation. The Court cited legal authorities stating that recovery will not be prevented because the consequences of an injury were aggravated by the employee's physical condition at the time of the injury, and that acceleration of a pre-existing disease or defect by an injury is compensable. The fact that the employee suffered from impaired vision prior to the accident does not prevent the loss or further impairment from constituting a compensable injury. On the issue of absolving the company from liability: The Court found merit in the petitioner's contention. The Employer's Report of Accident or Sickness, signed by the company's personnel manager, indicated "No" for controversion, meaning the company would not contest the claim. Furthermore, the report explicitly answered "Yes" to the question of whether the petitioner was injured in his regular occupation and described the accident as a "speck of coconut shell hit his (petitioner's) eye" while shelling coconuts. The Court reiterated the rule that when an employer does not controvert a claim, they are deemed to have waived their right to interpose any defense and cannot prove anything in relation thereto. Thus, the company was not relieved of its responsibility.
Main Doctrine
An employer is liable for compensation under the Workmen's Compensation Act when an injury sustained by an employee during the course of employment aggravates a pre-existing condition or injury sustained outside of employment, especially when the employer's report indicates no controversion of the claim and admits the injury occurred during regular occupation.