Central Azucarera Don Pedro v. Agno
REITERATIONFacts
The Antecedents: Respondent Elias Agno, employed by petitioner Central Azucarera Don Pedro since 1927, initially as a cane unloader and later as head mechanic in the centrifugating department, ceased working for the company on January 30, 1959. A medical examination on April 16, 1959, revealed moderately advanced tuberculosis in his left lung. Agno had been married three times and had nine children from his second marriage. Procedural History: The Workmen's Compensation Commission (WCC) issued an award in favor of respondent Elias Agno, ordering petitioner Central Azucarera Don Pedro to pay P4,000.00 as compensation, cover medical expenses, pay P41.00 as burial expenses, and award attorney's fees. The petitioner sought a review of this award before the Supreme Court, challenging the findings of the WCC regarding the origin of Agno's illness and the extent of his disability. The Petition: Petitioner Central Azucarera Don Pedro seeks review of the WCC award, primarily arguing that the Commission abused its discretion in finding that respondent Agno's tuberculosis was contracted during his employment and was traceable to his work conditions. The petitioner also contests the award for total disability benefits, asserting that individuals with tuberculosis are not necessarily totally disabled. Lastly, the petitioner questions the WCC's authority to award attorney's fees without a specific prayer or evidentiary basis in the proceedings.
Issue(s)
Whether the Workmen's Compensation Commission erred in finding that respondent Agno's tuberculosis was contracted during and traceable to his employment. Whether respondent Agno is totally disabled by reason of tuberculosis. Whether the Workmen's Compensation Commission may award attorney's fees motu proprio in the absence of a prayer and evidence thereof.
Ruling
The decision of the Workmen's Compensation Commission is modified by striking out the award of attorney's fees, but affirmed in all other respects.
Ratio Decidendi
On the issue of whether the WCC erred in finding that respondent Agno's tuberculosis was contracted during and traceable to his employment: The Court held that the petitioner's claim is untenable. The finding of the Commission that Agno became sick during his employment and that his sickness was traceable to the working conditions need not be proved directly, as it can be inferred from duly established facts by substantial evidence. The inference made by the Commission was not arbitrary. Furthermore, the statutory presumption is that the claim is compensable unless the employer proves otherwise. The employer failed to provide adequate evidence that Agno was free from tuberculosis when he ceased working or that the disease could have progressed to its advanced stage between January and April 1959. The Court cited Blue Bar Coconut Co. vs. Lugod and Agustin vs. WCC, et al. in support of its reasoning. On the issue of whether respondent Agno is totally disabled by reason of tuberculosis: The Court found the petitioner's argument that persons afflicted with tuberculosis are not totally disabled to be without merit. The evidence presented, including the X-ray examination showing moderately advanced tuberculosis, the claimant's complete stoppage from work, and the lack of evidence that the company desired to re-employ him even on a part-time basis, indicated that the claimant was indeed too sick to work. The Court rejected the petitioner's suggestion for a 50% reduction in disability compensation, characterizing it as a "remorseless insistence to extract the last ounce of energy from a sick man." The burden was on the employer to prove how much work the laborer could perform without detriment to his health, a burden which was not met. On the issue of whether the WCC may award attorney's fees motu proprio in the absence of a prayer and evidence thereof: The Court ruled that the WCC acted without authority in awarding attorney's fees ex parte. While Section 47 of Act 3428, as amended, empowers the Commission to approve and fix attorney's fees, this power is contingent upon a prayer for such fees and a basis established by evidence. Section 31 of the Act, which contemplates the relation between a claimant-employee and his lawyer, and Section 6 of Rule 26 of the WCC rules, along with Article 2208 of the Civil Code, do not grant the Commission motu proprio authority to make such an award when not requested or justified. The Court cited National Development Co. vs. Workmen's Compensation Commission, et al.
Main Doctrine
The Workmen's Compensation Commission has no authority to award attorney's fees motu proprio when the same have not been prayed for by the claimant nor has their amount been justified by evidence.