Plywood Industries v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Arsenio Manaoat, employed by Plywood Industries, Inc. as a splicer-receiver and later splicer-operator, developed back and chest pains accompanied by persistent coughing in April and May of 1957. Despite initial treatment by the company physician, his condition persisted, leading to an X-ray examination and subsequent diagnosis of tuberculosis. Findings also indicated that Manaoat's workplace was hot and dusty, potentially contributing to his illness. Procedural History: Manaoat reported his symptoms to his employer, who referred him to the company physician. After diagnosis of tuberculosis, the company physician advised him to stop working and informed him of a 60% wage payment. Manaoat sought further treatment in his hometown, where subsequent X-rays showed mixed results regarding the progression of his tuberculosis. The Workmen's Compensation Commission, affirming the decision of Labor Regional Office No. 1, awarded Manaoat compensation benefits under the Workmen's Compensation Act. The Petition: Plywood Industries, Inc. filed a petition for certiorari seeking to reverse the decision of the Workmen's Compensation Commission. The company contested the compensability of Manaoat's claim, arguing that the tuberculosis was not proven to be directly caused by or aggravated by his employment. They also raised issues regarding the late filing of notice of injury or sickness and the jurisdiction of the labor regional office. The Supreme Court denied the petition, finding that the Commission's factual findings were supported by substantial evidence and admissions from the company, and that the procedural arguments were either waived or did not constitute error.
Issue(s)
Whether the tuberculosis contracted by Arsenio Manaoat is compensable under the Workmen's Compensation Act, as amended, considering the nature of his employment. Whether the claim for compensation was filed within the prescribed period under Sections 26 and 27 of Act 3428, as amended. Whether Labor Regional Office No. 1 had jurisdiction to hear and decide the case.
Ruling
The petition for certiorari is denied, with costs against the petitioner company.
Ratio Decidendi
On the compensability of the illness: The Court held that the petitioner company's defense that the tuberculosis was not directly caused by employment or aggravated by it was without merit. The findings of fact by the Workmen's Compensation Commission, supported by substantial evidence, contradicted the company's claim. Crucially, the employer's own reports (W.C.C. Forms Nos. 3 and 4) attested that Manaoat was suffering from "Kock's pulmonary, minimal, right" while in their employ, and explicitly stated that the cause of the illness was "occupational." This admission, coupled with the company physician's diagnosis and treatment, established the causal link between the employment and the illness. The Court emphasized that these findings were based on Section 2 of Act 3428, which governs the compensability of injuries or illnesses. On the timeliness of the claim: The Court found that the petitioner company's argument regarding the late filing of the notice of injury or sickness was also unavailing. While Sections 26 and 27 of Act 3428, as amended, require timely filing, Section 26 explicitly provides an exception. This exception applies when medical services and supplies have been furnished and compensation payments have been made voluntarily by the employer. The records showed that the company physician treated Manaoat for tuberculosis, and the employer admitted to voluntarily paying P70.00 in compensation. These actions by the employer effectively dispensed with the strict time limits for filing the notice and claim. On the jurisdiction of the Regional Office: The Court clarified that the petitioner company's argument concerning the venue of the hearing was a matter of venue, not jurisdiction, and was being raised for the first time. Even if considered, the claim was properly heard in Regional Office No. 1 because the claimant, Arsenio Manaoat, was a resident of Lingayen, Pangasinan, as provided for in Section 1, Rule 16 of the Rules of the Workmen's Compensation Commission, which allows claims to be filed and heard where the claimant resides.
Main Doctrine
The employer's admission of liability and voluntary payment of compensation benefits, as well as the company physician's report stating the illness as occupational, estops the employer from controverting the claim for compensation under the Workmen's Compensation Act, as amended. Furthermore, the time limits for filing notice of injury or sickness are dispensed with when medical services have been furnished and compensation payments have been made voluntarily by the employer.