Basaysay v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Pedro Basaysay, an employee of Elizalde Paint & Oil Factory, Inc., contracted tuberculosis during his employment. The company provided medical and hospital treatment and paid his full wages during his periods of disability. The core dispute centers on whether Basaysay's tuberculosis was service-connected or aggravated by his employment, and whether his condition was arrested by the time of his discharge. Procedural History: Basaysay filed a claim for compensation with the Workmen's Compensation Commission. A hearing officer initially ruled in favor of Basaysay, ordering the company to pay P2,183.00 for medical expenses incurred after his discharge and to pay fees. However, upon review and reconsideration, an Associate Commissioner reversed this decision, dismissing the claim. The Commission en banc unanimously denied a further motion for reconsideration, leading to the present appeal. The Petition: Petitioner Pedro Basaysay seeks review by certiorari of the Workmen's Compensation Commission's decision. He argues that the Commission erred in giving weight to the testimony of Dr. Conrado Lorenzo, the company's consultant, regarding the arrest of his tuberculosis. Basaysay contends that this testimony, which formed the basis for the Commission's reversal of the hearing officer's award, should have been disregarded. The Supreme Court's review is limited to questions of law, and it generally does not re-examine findings of fact unless there is a grave abuse of discretion.
Issue(s)
Whether the Supreme Court can review the findings of fact made by the Workmen's Compensation Commission in an appeal by certiorari. Whether the petitioner's tuberculosis was already arrested on his last day of work, January 2, 1958.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission dismissing the claim, without costs.
Ratio Decidendi
On the issue of reviewing findings of fact in an appeal by certiorari: The Court held that in appeals by certiorari, such as the one before it, the findings of fact made in the decision appealed from will not be reviewed by the Supreme Court. This is a well-settled principle in Philippine jurisprudence. The Court's authority in such appeals is limited to questions of law. The only exception is when there has been a grave abuse of discretion in making said findings, which must be due to the total absence of competent evidence to support them. In this case, the Court found that competent and substantial evidence existed to support the findings of the Commission. Therefore, the petitioner's contention that the Supreme Court should review the factual findings was untenable. On whether the petitioner's tuberculosis was already arrested on his last day of work: The Court did not directly rule on this substantive issue but rather on the procedural limitation of its review power. The decision of the Workmen's Compensation Commission, which reversed the hearing officer's award, relied principally on the testimony of Dr. Conrado Lorenzo, the respondent's consultant. The petitioner argued that this testimony should not have been given weight because Dr. Lorenzo was the respondent's consultant. However, the Supreme Court, in an appeal by certiorari, cannot ascertain the credibility and weight of conflicting evidence. This task is beyond its province. Since competent evidence existed to support the Commission's finding that the ailment was arrested, the Court could not substitute its own judgment on the matter. The essential question of whether the ailment was arrested hinged on the determination of whether claimant was entitled to medical and hospital services after his discharge, a factual determination made by the Commission.
Main Doctrine
In appeals by certiorari, the Supreme Court will not review findings of fact unless there has been a grave abuse of discretion due to the total absence of competent evidence. The task of ascertaining the credibility and weight of conflicting evidence is beyond the province of the Court in such appeals.