National Power Corporation v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Enrique Gulmatico, an assistant stockman for the National Power Corporation (NPC) earning P140.00 monthly, performed various duties including checking materials, issuing supplies, arranging equipment, acting as stockkeeper, and running errands within the plant. He frequently worked overtime during emergencies, often missed lunch, and stayed late to close the warehouse. On November 4, 1956, a Sunday, Gulmatico was asked to work overtime pumping gasoline to vehicles. He went home for lunch, experiencing stomach pain, but returned to work. That evening, his stomach pain intensified, accompanied by vomiting. After initial treatment by the plant physician, he was transferred to a hospital for an operation, but his death occurred due to a sudden drop in blood pressure. The physician certified the cause of death as a ruptured chronic perforating gastric ulcer, acute generalized peritonitis, and toxemia. Procedural History: Gulmatico's widow, Dominica Luna, filed a compensation claim with the Department of Labor. A hearing officer awarded P4,000.00 in compensation and P200.00 for burial expenses. The employer appealed this decision to the Workmen's Compensation Commission (WCC), which upheld the award. The National Power Corporation subsequently filed a petition for review with the Supreme Court. The Petition: The National Power Corporation (NPC) contested the claim, not on the basis of the sickness's compensability, but on the grounds that the WCC had not acquired jurisdiction. NPC argued that the claim was filed beyond the three-month period stipulated in Section 24 of the Workmen's Compensation Act, noting that the deceased died on November 5, 1956, while the claim was filed on December 2, 1958.
Issue(s)
Whether the death of Enrique Gulmatico due to a ruptured gastric ulcer aggravated by his work is compensable under the Workmen's Compensation Act. Whether the claim for compensation was filed within the statutory period, or if the employer is estopped from raising the defense of prescription.
Ruling
The decision appealed from is affirmed. No costs.
Ratio Decidendi
On the compensability of the illness: The Court affirmed the WCC's finding that while ulcer is not inherently an occupational disease, it was seriously aggravated by the nature of Gulmatico's work. The irregular hours, missed meals, and overtime work, especially the manual pumping of gasoline on November 4, 1956, which exposed him to gasoline fumes, contributed to the aggravation of his condition. The Court noted that there was no evidence of the disease prior to his employment in 1951, but symptoms began in 1955 and worsened until his death in 1956, despite medical treatment provided by the employer's physician. The sickness was contracted in the course of employment and aggravated by the demands of the service, making it compensable under the law. On the prescription of the claim: The Court upheld the WCC's ruling that the employer, NPC, was estopped from claiming that the compensation claim was filed out of time. The WCC reasoned that NPC was aware of Gulmatico's death from the beginning, as its representatives, including the company physician and plant supervisor, attended the interment. Furthermore, NPC filed its "Employer's Report" only on December 11, 1958, after the claimant had already filed her notice and claim for compensation. The Court reiterated its stance, citing previous cases, that the failure to submit the required Employer's Report can be deemed a waiver of the defense of prescription, as this report serves as the employer's answer in compensation proceedings.
Main Doctrine
An illness that is aggravated by the irregular and intemperate nature of work, even if not inherently occupational, is compensable under the Workmen's Compensation Act. Furthermore, the failure of an employer to file the required Employer's Report of Accident or Sickness may be deemed a waiver of the defense that the claim for compensation was filed beyond the statutory period.