National Development Co. v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Guillerma Millano, a spinner for the National Development Company (NDC), alleged that while in a stooping position picking up bobbins on January 11, 1951, two heavy roves fell on her back, causing her to feel dizzy and spit blood. She was subsequently diagnosed with chronic, active, bilateral, moderately advanced pulmonary tuberculosis. Her medical treatment continued until October 1955, and her services with NDC were terminated effective upon the expiration of her leave privileges. Procedural History: Millano filed a claim for compensation. A hearing officer awarded her P2,995.20 for compensation, P1,800 for medical expenses, and P150 for attorney's fees. Upon NDC's petition for review, the Workmen's Compensation Commission (WCC) affirmed these awards, increasing attorney's fees and costs to P224.64 and P35.00, respectively. A motion for reconsideration was denied by the Commission en banc. The Petition: The National Development Company (NDC) filed a petition for certiorari with the Supreme Court, arguing that the WCC's decision made new findings of fact not supported by evidence and that the claimant's illness was not a result of her employment.
Issue(s)
Whether the Workmen's Compensation Commission made new findings of fact not supported by evidence. Whether the claimant's illness was a result of the nature of her employment.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, ordering the National Development Company to pay the awarded compensation and medical expenses, with costs against the petitioner.
Ratio Decidendi
On Issue 1: The Court found that the NDC's premise that the claim and award were based solely on aggravation was untrue. The claimant's complaint alleged that her work involved strenuous efforts, lifting heavy objects, and was performed under conditions conducive to the development and aggravation of tuberculosis, such as inhaling cotton dust, continuous night work, sudden temperature changes, and close contact with infected co-workers. The claimant also alleged she was free from tuberculosis when she started working for NDC and that her sickness was confirmed while in their employ. Therefore, the claim was based on both the development of the illness due to employment and its aggravation. The hearing officer's decision also considered both grounds, and the Associate Commissioner did not exceed his authority in affirming the decision. The Court was satisfied that the conclusion was supported by substantial evidence. On Issue 2: The Court found substantial evidence supporting the conclusion that the impairment of the claimant's health was a consequence of the nature of her employment and the conditions under which she had to work. The allegations in her complaint, detailing the strenuous nature of her work, the unhealthy conditions, and her prior good health, were sufficient to warrant the conclusion that her illness resulted from her employment. The fact that she was allowed to continue working under the same conditions despite the NDC's knowledge of her illness further supported the finding of aggravation. Thus, the claimant's illness was deemed to have arisen out of and in the course of her employment.
Main Doctrine
The Workmen's Compensation Commission's decision awarding compensation for pulmonary tuberculosis to an employee was affirmed, establishing that the illness was a consequence of the nature of her employment and the conditions under which she worked, which included strenuous tasks, exposure to dust, night work, temperature changes, and contact with infected co-workers. The Court found substantial evidence to support the conclusion that the claimant's illness was either caused by her employment or aggravated by it, and that the employer had knowledge of her condition.