Manila Railroad Company v. Perez
REITERATIONFacts
1. The Antecedents: Daniel Perez, employed by Manila Railroad Company since September 1, 1939, and later as a second-class assistant conductor, developed pulmonary tuberculosis. His work involved attending to passengers, assisting with luggage, and giving signals, with irregular hours sometimes starting as early as 3:00 a.m. or 3:00 p.m. Perez experienced symptoms of tuberculosis as early as 1940, including spitting blood, and received medical treatment, including artificial pneumothorax, in 1944 and 1946. His condition worsened over time, leading to his dismissal in 1944 due to prolonged absence and subsequent retirement on January 1, 1951, advised by his superior due to his deteriorating health. 2. Procedural History: After his retirement, Daniel Perez filed a claim for compensation with the Workmen's Compensation Commission on September 6, 1960. The petitioner, Manila Railroad Company, controverted the claim. The Chief Hearing Officer initially dismissed the claim on February 6, 1962, finding that the disease was not contracted in the course of employment and that its aggravation was due to natural development. However, this decision was reversed by the Acting Chairman of the Workmen's Compensation Commission, and the Commission en banc upheld this reversal upon motion for reconsideration, leading to the present appeal by certiorari. 3. The Petition: The Manila Railroad Company, as petitioner, appeals by certiorari from the decision of the Workmen's Compensation Commission. The petitioner argues that Perez's illness was not aggravated by his employment, that even if aggravated, it is not compensable as the disability occurred before the effectivity of Republic Act No. 772 which specifically included aggravation of tuberculosis as a compensable cause, and that the evidence supporting the awarded sums is insufficient. Additionally, the petitioner contends that the claim was filed out of time and had prescribed, and that the Commission lacked jurisdiction. The Supreme Court, however, finds that the aggravation of the pre-existing illness is compensable under existing law, that these defenses were not timely raised and thus waived, and that the sufficiency of evidence on amounts awarded is a factual matter not reviewable on certiorari.
Issue(s)
Whether the illness of respondent Daniel Perez was aggravated by the nature of his employment. Whether the aggravation of a pre-existing illness, which resulted in disability before the effectivity of Republic Act No. 772, is compensable under the original Workmen's Compensation Act. Whether the claim was filed within the prescribed period and had not prescribed. Whether the evidence sufficiently supported the award.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, ordering Manila Railroad Company to pay the compensation, medical expenses, and attorney's fees to Daniel Perez. The Court held that the illness was aggravated by the nature of employment and that the claim was compensable and not barred by prescription or untimeliness.
Ratio Decidendi
On the aggravation of illness: The Court found that while it was not clearly shown that the illness was contracted in the course of employment, the records satisfied the Commission that the illness was aggravated by the nature of the employment. The fact that the respondent spat blood several months after starting work suggested a pre-existing latent condition, which was worsened by his work. On compensability before Republic Act No. 772: The Court held that the legal consequence of aggravation of a pre-existing illness is not affected by the fact that it took place before June 20, 1952, the effectivity of Republic Act No. 772. The Court cited jurisprudence from the United States and its own ruling in Blue Bar Coconut Company, et al. vs. Joaquin Boo (G.R. No. L-6920, September 28, 1954) to the effect that compensation for disability from aggravation of a pre-existing illness has been granted even without specific statutory provisions, and that Republic Act No. 772 did not change the import of the employer's liability under the original Act. On waiver of defenses (timeliness and prescription): The Court ruled that the questions of whether the claim was filed beyond the two-month period and whether it had prescribed were not raised before the Commission, not even in the motion for reconsideration. These defenses were raised for the first time in the petitioner's brief, constituting a waiver. The Court reiterated that defenses must be pleaded in the employer's answer to the claim. Furthermore, the failure to file within the two-month period does not affect the Commission's jurisdiction, and compensation claims under the Act prescribe in ten years, which had not expired. On sufficiency of evidence for award: The Court stated that the sufficiency of evidence in support of the amounts awarded is a question of fact that cannot be reviewed on appeal by certiorari.
Main Doctrine
The aggravation of a pre-existing illness, even if occurring before the effectivity of Republic Act No. 772, is compensable under the original Workmen's Compensation Act (No. 3428), and defenses not raised before the Commission are deemed waived.