Catapang v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Federico Catapang was employed by Victorias Milling Company from 1934 to 1941 and again from 1946 until his hospitalization for pulmonary tuberculosis on June 23, 1951. Despite annual physical and X-ray examinations showing him negative for the disease until 1947, an X-ray in 1948 revealed minimal pulmonary tuberculosis. He continued working as an Issuer of Foodstuffs, a physically demanding job, while receiving intermittent anti-tuberculosis treatment. By June 23, 1951, his condition worsened to "far advanced pulmonary tuberculosis," leading to his hospitalization. He was released on September 15, 1951, but was declared medically unfit for work on September 30, 1951, and given a gratuity pay of P1,700.00. Procedural History: The Hearing Officer of the Workmen's Compensation Commission (WCC) found the disease compensable, awarding P3,000.00 and medical services. However, the WCC en banc reversed this decision, ruling that Catapang was not covered by the law then in force because his remuneration exceeded P42.00 a week. The WCC en banc relied on Section 39(b) of Act 3428, as amended, which excluded employees earning more than P42.00 weekly. The WCC noted that Republic Act No. 772, enacted in 1952, eliminated this salary limit but could not be applied retroactively. The Petition: Petitioner elevated the case to the Supreme Court after the WCC en banc denied his motion for reconsideration.
Issue(s)
Whether the basis for computing the average weekly wage under Section 19 of Act No. 3428 should be the salary at the time of severance or the average earnings during the twelve weeks immediately preceding the date of disability.
Ruling
The Supreme Court reversed the decision of the Workmen's Compensation Commission en banc. It held that petitioner Federico Catapang is entitled to compensation. The case was remanded to the WCC for computation of the compensation amount. Victorias Milling Company was ordered to pay costs and P225.00 in attorney's fees.
Ratio Decidendi
On Issue 1: The Supreme Court held that the computation must be based on the 12-week period preceding the 'disability,' which in this case occurred on June 23, 1951, when Catapang was hospitalized and completely disabled for work. Section 19 of Act No. 3428 explicitly provides that average weekly wages shall be computed from the earnings of the laborer 'during the twelve weeks next preceding his injury.' Applying this, the 12-week lookback period spans from March 31, 1951, to June 22, 1951. During most of this period (until June 1), Catapang was earning only P170.00 per month. His average weekly wage during this specific statutory window was P39.23, which is below the P42.00 limitation set by the law then in force. The Court emphasized that the purpose of using the 12-week window next preceding disability is to measure the actual loss to the family due to the illness. Furthermore, the Court observed that the salary increase to P200.00 and the subsequent discharge appeared 'timed to coincide with the ultimate pattern to make him fall under the category of employees not covered by the law,' characterizing such an act as a subtle way of defeating the worker's right to compensation under the guise of benevolence.
Main Doctrine
The computation of average weekly wages for compensation purposes under the Workmen's Compensation Law should be based on the earnings during the twelve weeks immediately preceding the disability, and the salary limit exclusion should be applied based on the law in force at the time of the disability, not on subsequent amendments.