Iloilo Dock & Engineering Co. v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Pablo Santiago, an iron worker for Iloilo Dock & Engineering Company, suffered a "slight compression fracture of the 12th thoracic vertebrae" on August 16, 1955, while repairing a lighter, which incapacitated him for 14-6/7 weeks. The company physician certified a "partial permanent disability of the back due to slight stiffness at the 12th thoracic vertebrae — 20% (of back)". The petitioner company filed an Employer's Report of Accident and stated it would not controvert Santiago's claim for compensation. 2. Procedural History: Santiago returned to work on December 1, 1955, performing his usual tasks without complaint and receiving the same wages. The Regional Administrator awarded Santiago P1,148.10 in compensation, covering medical services, temporary total disability (P344.39), and permanent partial disability under Section 18 (P803.71). The petitioner paid the first two items but contested the award for permanent partial disability. The Workmen's Compensation Commission affirmed the Labor Administrator's ruling, and a subsequent appeal to the Commission en banc was denied. 3. The Petition: The petitioner filed a petition for certiorari, alleging that the Labor Administrator lacked jurisdiction to make the award and that the Commission erred in considering the injury compensable under Section 18 of the Workmen's Compensation Act.
Issue(s)
Whether the Labor Administrator had jurisdiction to make the award despite the absence of a formal hearing. Whether the injury sustained by Pablo Santiago is compensable under Section 18 of the Workmen's Compensation Act. Whether the compensation award under Section 18 was properly computed despite Santiago receiving the same wages upon return to work.
Ruling
The petition is dismissed, and the decision subject of review is affirmed.
Ratio Decidendi
On the Labor Administrator's Jurisdiction: The Court held that the Labor Administrator had jurisdiction. The petitioner's failure to controvert Santiago's claim within the prescribed period, as indicated by its statement that it would not controvert the claim, constituted a renunciation of its right to controvert. Under the rules of the Workmen's Compensation Commission, when an employer fails to controvert, the Hearing Officer may proceed to make an award based on the claimant's evidence, treating the claim as uncontested. The petitioner's argument that no hearing was conducted to present its evidence was rendered moot by its prior declaration not to controvert the claim. The Commission's affirmation of the Administrator's award, therefore, was made with jurisdiction and without grave abuse of discretion, citing The Bachrach Motor Co., Inc. v. The Commission, et al.. On Compensability under Section 18: The Court ruled that Santiago's injury was compensable under Section 18 of the Workmen's Compensation Act. While Section 18 is titled "Amputation," the Court clarified that the title does not limit its application solely to amputations. The section explicitly includes compensation for "serious disfigurement of the face or head" and, crucially, for "all other cases of this kind of disability not mentioned in other sections of this Act." Santiago's "slight compression fracture of the 12th thoracic vertebrae" resulting in "partial permanent disability of the back due to slight stiffness" was deemed a disability of a similar nature and not covered by other sections, thus falling within the purview of the general provision of Section 18. On the Computation of Compensation: The Court rejected the petitioner's argument that compensation could not be computed because Santiago received the same wages upon returning to work. The Court emphasized that the criterion under the law is "earning capacity" and not merely the wages received after the injury. It explained that wages can be affected by extraneous factors, and an employee may still have suffered an impairment of earning capacity even if their post-injury wages are the same or higher. The Court cited Azucarera de Don Pedro v. De Leon & Alla to support the principle that earning capacity is the basis for compensation, not just current wages. The Court further reasoned that a permanent impairment, like the loss of an arm, should be compensated regardless of subsequent employment and wages, as it represents a permanent partial disability contemplated by the Act.
Main Doctrine
The Workmen's Compensation Act is to be construed liberally in favor of employees, and an injured laborer's capacity for work is measured by their earning capacity, not solely by the wages received after injury, as factors extraneous to wages can affect earning capacity.