Hernandez v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Ciriaco Hernandez was employed by Manila Electric Company (MERALCO) as an automotive mechanic from May 15, 1930. On January 15, 1953, after 23 years of service, he was diagnosed with pulmonary tuberculosis. He also contracted inguinal hernia in 1954 and carcinoma of the prostate in 1959, both requiring surgery. MERALCO advised Hernandez of his retirement on December 31, 1959, pursuant to company policy. However, at his request, he was retired earlier on November 25, 1959, at age 69, and received his retirement benefits. Procedural History: On March 10, 1960, Hernandez filed a Notice of Sickness and Claim for Compensation, later amended. The Department of Labor, Regional Office No. 4, awarded him P4,000.00 as temporary total disability compensation. MERALCO appealed to the Workmen's Compensation Commission (WCC), which reversed the hearing officer's decision. The WCC, en banc, affirmed this reversal upon motion for reconsideration. The Petition: Hernandez sought review of the WCC's decision, arguing that his retirement was due to his illness, not his age, and that the WCC erred in denying compensation for his pulmonary tuberculosis.
Issue(s)
Whether petitioner's pulmonary tuberculosis, which manifested after 23 years of employment, is compensable under the Workmen's Compensation Act. Whether petitioner's retirement, which occurred 36 days before his scheduled retirement date, was due to his illness and entitles him to compensation for that period. Whether the claim for compensation had prescribed.
Ruling
The Supreme Court reversed the decision of the Workmen's Compensation Commission. MERALCO was ordered to pay petitioner compensation at the rate of P35.00 per week for the period from November 25, 1959, to December 31, 1959, exclusive of the first three days. Respondent was also ordered to pay expenses to the WCC.
Ratio Decidendi
On the compensability of pulmonary tuberculosis: The Court held that the WCC erred in rejecting compensation for tuberculosis solely because it took 23 years to manifest. Citing Agustin vs. WCC, the Court reiterated that once a disease is shown to have arisen in the course of employment, it is presumed by law to have arisen out of it, absent substantial evidence to the contrary. The fact that 23 years elapsed before the disease appeared is not substantial evidence to rebut this presumption. The Court found the WCC's speculation insufficient and contrary to the statutory presumption. The employer's report stating Hernandez retired due to "minimal PTB, bilateral, fibroid" further supported the claim that the sickness was contracted in the course of employment and was responsible for his retirement. The Court emphasized that the slow deterioration of health due to working conditions does not negate the causal link between employment and the disease. On compensation for the period before scheduled retirement: The Court ruled that petitioner is entitled to compensation for the 36 days between his actual retirement (November 25, 1959) and his scheduled retirement (December 31, 1959). It found that Hernandez was forced to retire early not due to old age but due to his weakened bodily condition from illness. His earning capacity, independent of his sickness, ended on December 31, 1959, the date he would have been compulsorily retired. Compensation payments are premised on the loss or impairment of earning capacity due to illness or injury, and thus cannot extend beyond the date his earning capacity would have ceased regardless of sickness. However, the employer's obligation to provide medical and hospital services subsists until the illness is cured or arrested, even beyond the cessation of compensation payments. On the alleged prescription of the claim: The Court found that MERALCO's voluntary furnishing of medical services and supplies dispensed with the need for Hernandez to file his Notice of Sickness within the statutory time limit. Regarding the two-month period for filing a claim for compensation, the Court held that it should be counted from the date the employee becomes physically disabled to work. Hernandez was disabled on November 25, 1959. His request for retirement on that date, predicated on sickness causing his disability to work until his scheduled retirement, substantially fulfilled the requirement of a claim, preventing MERALCO from claiming surprise. The Court calculated the applicable average weekly wage and determined the weekly compensation rate for the period in question.
Main Doctrine
The presumption of compensability under the Workmen's Compensation Act applies once a disease is shown to have arisen in the course of employment, and the employer must present substantial evidence to prove otherwise. The mere passage of time before a disease manifests does not, by itself, rebut this presumption.