Philippine Iron Mines v. Abear
REITERATIONFacts
The Antecedents: Respondent Tomas Abear, an employee of petitioner Philippine Iron Mines, Inc. since 1934, suffered an accident in 1936 resulting in the amputation of his left leg below the knee. He received P600.00 in compensation benefits for this. Abear returned to work as a bolt threader, using a home-made caliper. On January 12, 1957, he slipped and fell on a cement floor, causing his leg stump to bleed profusely. This necessitated a surgery on February 19, 1957, resulting in the amputation of his left leg above the knee. He continued working in a lighter capacity until he was laid off on November 30, 1961, due to a retrenchment policy. Procedural History: On August 20, 1962, a physician from the Workmen's Compensation Commission (WCC) found Abear to have a 100% permanent partial disability of the left leg. Abear filed a claim for compensation based on the loss of his leg above the knee. An Associate Commissioner of the WCC granted the claim, which was affirmed by the Commission. The Petition: Petitioner Philippine Iron Mines, Inc. sought review by certiorari, arguing that Abear's claim was barred by the statute of limitations and that the compensation paid in 1936 for the lower leg amputation should be deducted from the compensation for the upper leg amputation in 1957.
Issue(s)
Whether the claim for compensation is barred by the statute of limitations. Whether compensation paid for the prior amputation of the left leg below the knee should be deducted from the compensation due for the subsequent amputation of the left leg above the knee.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, holding that the claim was not barred by prescription and that no deduction should be made for compensation previously paid for the lower leg amputation.
Ratio Decidendi
On the issue of prescription: The Court held that the defense of prescription, based on the claim not being filed until August 2, 1962, despite the accident on January 12, 1957, could not be entertained. This is because petitioner failed to set up this defense in the Workmen's Compensation Commission. It is a well-settled principle that the benefits of the statute of limitations cannot be invoked for the first time on appeal; the defense is deemed waived if not seasonably pleaded in the lower court. Furthermore, the petitioner's failure to report the accident to the WCC within the prescribed period, despite knowledge of the incident and Abear's confinement, meant that petitioner was deemed to have "renounced the right to controvert" the claim pursuant to Section 45 of Act No. 3428, as amended. On the issue of deduction of prior compensation: The Court ruled that no deduction can be made for compensation paid in 1936 for the amputation of Abear's left foot below the knee from the compensation due for the amputation of the left leg above the knee in 1957. The Court cited the well-settled principle that such deduction is not permissible unless the law explicitly provides for it, and there is no such provision in Philippine laws. The Court referenced foreign jurisprudence, such as Knoxville Knitting Mills v. Galyon, Industrial Commission v. State Ins. Compensation Fund, Schwab v. Emporium Forestry Co., and Branconnier's Case, which support the view that prior disabilities or losses do not reduce compensation for a subsequent, distinct injury. The Court emphasized that Section 17 of Act No. 3428, as amended, provides a fixed compensation for permanent partial disability, and judicial fiat cannot add a qualification to this provision by deducting prior compensation. The Court acknowledged that this strict interpretation might sometimes be detrimental to employees by deterring re-engagement but stated that the language of the law leaves no discretion. The Court also noted that jurisdictions have resorted to insurance or amendments providing for deduction (apportionment statutes) to offset potential hardship, but courts are limited to applying the law as written.
Main Doctrine
The statute of limitations defense is deemed waived if not seasonably pleaded in the lower court. Furthermore, compensation paid for a previous loss cannot be deducted from compensation due for a subsequent, distinct loss unless the law explicitly provides for such deduction.