National Development Co. v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Respondent Gertrudes Lucas Vda. de Raymundo filed a claim for workmen's compensation for the death of her husband, Luis Raymundo, who was employed by petitioner National Development Co. for over 12 years. Luis Raymundo's work involved strenuous activities, including lifting heavy loads, pushing wagons, and mixing chemicals, often performed at night and involving exposure to sudden temperature changes. Due to poor health, he retired on May 6, 1953, and died eight months later, on January 23, 1954, of pulmonary tuberculosis. Procedural History: Respondent filed a complaint before the Department of Labor, averring that her husband's strenuous work and exposure to chemicals and temperature changes led to his illness, which eventually caused his death. Petitioner denied liability, asserting that tuberculosis was not an occupational disease and that the claim was barred by prescription. The Regional Office rendered a decision ordering petitioner to pay death compensation and burial expenses. This decision was affirmed by the Workmen's Compensation Commission (WCC) en banc, which found that the deceased contracted pulmonary tuberculosis while in petitioner's employ and that his work likely had an adverse effect on his illness. The Petition: Petitioner appealed to the Supreme Court, raising issues regarding the admissibility of evidence, recovery of death benefits for an aggravated illness, and prescription of the claim.
Issue(s)
Whether the evidence presented by respondent is admissible to support an award in her favor. Whether death benefits could be recovered where the illness causing death was not contracted during employment but was merely aggravated by the nature of such employment. Whether respondent's claim was barred by prescription.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, upholding the award of death compensation and burial expenses to respondent Gertrudes Lucas Vda. de Raymundo. The Court ruled that the evidence presented was admissible, that death benefits are recoverable even if the illness was aggravated by employment, and that the claim was not barred by prescription.
Ratio Decidendi
On the admissibility of evidence: The Court held that the testimony of respondent and documentary evidence such as the death certificate (Exhibit "E"), the affidavit of the attending physician (Exhibit "F"), and the employer's letter of termination (Exhibit "G") were admissible under Section 49 of the Workmen's Compensation Act. While these might be considered hearsay under common law rules, Section 49 allows for a more liberal reception of evidence in compensation proceedings to ensure fairness to workers. The Court clarified that a party's testimony in court is not self-serving evidence, as it is sworn and subject to cross-examination. Furthermore, the Court noted that even if some evidence were hearsay, it was admissible to aid in determining facts, provided there was other substantial evidence supporting the award, such as the testimony of a co-employee and evidence of gratuity payment. The presumption under Section 44 also supported the admissibility and correctness of verified medical reports. On recovery for aggravated illness: The Court ruled that death benefits are recoverable even if the illness causing death was not contracted during employment but was merely aggravated by the nature of such employment. Although Section 8 of the Act specifically mentioned "disease contracted" or "injury received," the Court considered the insertion of "illness ... aggravated by ... the nature of such employment" in Section 2 by Republic Act No. 772 as a ground for compensation. The Court reasoned that the omission to amend Section 8 was a mere oversight, as Section 8 primarily governs the amount of compensation, while Section 2 provides the grounds. Therefore, Section 8 should be interpreted to cover cases of aggravation. On prescription of the claim: The Court found that petitioner could not set up the defense of prescription for several reasons. Firstly, petitioner failed to controvert the claim, which precluded it from later asserting that the claim was not filed on time. Secondly, petitioner's act of paying gratuity to Raymundo under a policy for retiring employees with tuberculosis excused the delay in filing the claim. Thirdly, petitioner demonstrated no damage resulting from the delay, which, under Section 27 of the Act, also excuses delays in filing claims. Thus, the claim was not barred by prescription.
Main Doctrine
The Workmen's Compensation Act allows compensation for illnesses aggravated by the nature of employment, even if not contracted during employment. Hearsay evidence, while subject to scrutiny, is admissible under Section 49 of the Act to aid in determining facts, provided there is other substantial evidence. The presumption under Section 44 shifts the burden of proof to the employer to disprove aggravation.