Batangas Transportation Co. v. Perez
REITERATIONFacts
1. The Antecedents: Tomas Perez, a bus driver for Batangas Transportation Company, sustained injuries including contusions and abrasions in an accident on January 20, 1957, while operating a company bus. Following the accident, he began experiencing a severe cough and general weakness. Despite initial treatments by the company physician for various ailments, his condition worsened, leading to a diagnosis of pulmonary tuberculosis on March 2, 1958. He was subsequently dismissed by the company on October 18, 1958, due to his prolonged absence from work. 2. Procedural History: After his dismissal, Tomas Perez sought compensation under the Workmen's Compensation Act. A hearing officer initially ordered Batangas Transportation Company to pay Perez P3,303.72 in compensation, plus P23.94 weekly until his illness was arrested or the maximum compensation of P4,000.00 was reached, and to provide necessary medical services. The company filed a motion for reconsideration, which led to the elevation of the case to the Workmen's Compensation Commission. The Commission affirmed the award, finding the pulmonary tuberculosis to be a result of the employment and the accident, and also ordered the company to pay P300.00 in attorney's fees. 3. The Petition: Batangas Transportation Company filed a petition for certiorari with the Supreme Court, challenging the Commission's decision. The company argued that the Commission erred in finding that Perez's pulmonary tuberculosis was a result of his employment, in ordering the payment of P4,000.00 compensation, in requiring the provision of medical services, and in awarding attorney's fees. The Supreme Court affirmed the Commission's judgment in its entirety, except for the award of attorney's fees, which was eliminated as Perez had not appealed the hearing officer's decision.
Issue(s)
Whether the respondent Commission committed a grave abuse of discretion in finding that the illness (pulmonary tuberculosis) of respondent Tomas Perez was "the result of the nature of his employment". Whether the respondent Commission committed a grave abuse of discretion and an error in law in ordering the petitioner to pay respondent Tomas Perez P4,000.00 as compensation. Whether the respondent Commission committed an error in law in ordering the petitioner to provide respondent Tomas Perez with medical, surgical and hospital services and supplies. Whether the respondent Commission committed an error in law in ordering the petitioner to pay respondent Tomas Perez P300.00 as attorney's fees.
Ruling
The judgment of the Workmen's Compensation Commission is affirmed, with the elimination of the amount for attorney's fees.
Ratio Decidendi
On the finding that pulmonary tuberculosis was the result of the nature of employment: The Court affirmed the Commission's finding, stating that under Section 2 of the Workmen's Compensation Act, an illness is compensable if directly caused by employment, aggravated by employment, or resulted from the nature of employment. While the accident on January 20, 1957, may not have directly caused the incipient pulmonary tuberculosis, it established a causal relation by reducing Perez's vitality and resistance, making him more susceptible. The prolonged and taxing nature of his employment, involving long hours, difficult road conditions, and immediate post-trip duties, further aggravated the condition and hastened the attack of the disease, even if the diagnosis of tuberculosis came thirteen months after the accident. The Court emphasized that tuberculosis is an imperceptible germ disease whose incipient stage may not be readily discovered, and factual issues of causality are primarily for the Commission to decide. On the award of P4,000.00 as compensation: The Court found no merit in the petitioner's argument that Perez's disability had ceased as of April 1, 1959, based on the testimony of Dr. Cirilo Santos. Dr. Santos's testimony merely stated a possibility that Perez might have been cured, not a definitive statement that he was. In contrast, Perez testified that he was still taking medication, experiencing weakness, and coughing as of March 18, 1960. The Court reiterated its policy to liberally construe the Workmen's Compensation Act as social legislation and held that the Commission's factual findings are generally binding upon the Supreme Court unless there is gross abuse. On the order for medical, surgical, and hospital services: The Court applied the same reasoning as in the first assignment of error. Factual issues regarding the employee's continued suffering from the illness are primarily for the Commission to decide. The argument that the employer-employee relationship must exist at the time of the decision to justify such an award was deemed absurd, as it would allow employers to evade obligations by dismissing employees upon indication of illness. On the award of P300.00 as attorney's fees: The Court found merit in this argument. It is a settled rule that in appellate courts, no additional award may be given to a party who has not appealed. Since Tomas Perez did not appeal the decision of the Hearing Officer, the award of attorney's fees was eliminated.
Main Doctrine
The Workmen's Compensation Act, being a social legislation designed to provide relief to workmen, must be liberally construed. An illness contracted during employment, even if not directly caused by it, is compensable if it was aggravated by the employment or resulted from the nature of the employment, especially when an accident during employment reduced the employee's vitality and resistance to disease. An employer cannot evade liability by dismissing an employee after an illness is indicated.