National Shipyards and Steel Corporation v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Dr. Oliver B. Coronado, a company physician employed by the National Shipyards and Steel Corporation (NASSCO) at its Iligan Steel Mills, was assigned to airlift an emergency case. During this assignment, he suffered from "Angiospastic Retinopathy" in his left eye, resulting in bodily pain, medical treatment, and a 70% loss of vision in the affected eye. Procedural History: Dr. Coronado filed a claim for compensation with the Workmen's Compensation Commission. The employer, NASSCO, resisted the claim. The case was heard by Regional Office No. XI, which issued an award that was affirmed, with slight modifications, by the Commission. NASSCO's motion for reconsideration was denied. The Petition: NASSCO filed a petition with the Supreme Court seeking to reverse the award of the Workmen's Compensation Commission, which ordered NASSCO to pay Dr. Coronado compensation, medical expenses, attorney's fees, and administrative fees.
Issue(s)
Whether Regional Office No. XI had jurisdiction to hear the claim under Reorganization Plan 20-A. Whether a company physician is considered an industrial employee covered by the Workmen's Compensation Act. Whether Dr. Coronado's annual earnings exceeding P4,800.00 exclude him from the coverage of the Workmen's Compensation Act. Whether the hearing officer erred in closing the trial without allowing NASSCO to complete its evidence. Whether the decision of the Commission is supported by substantial evidence.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission. The award in favor of Dr. Oliver B. Coronado was upheld, and the petition of the National Shipyards and Steel Corporation (NASSCO) was denied.
Ratio Decidendi
On the jurisdiction of Regional Office No. XI: The Court held that Regional Office No. XI had jurisdiction to hear the claim. Citing previous holdings, the Court stated that Section 25 of Reorganization Plan 20-A merely reallocated powers already possessed by the Department of Labor, consistent with Republic Act No. 997, as amended by Republic Act No. 1241. The hearing officers of the regional offices act as referees appointed by the Commission and do not possess independent judicial power. On whether a company physician is an industrial employee covered by the Act: The Court ruled that a company physician is covered by the Workmen's Compensation Act. Section 3 of the Act expressly applies to "employees and laborers employed... in the industrial concern of the government" and "all other persons performing manual labor in the service of the National Government and its political subdivisions or instrumentalities." The Court clarified that the fact that Dr. Coronado does not perform manual labor does not exempt him from the Act's coverage. On the effect of earnings exceeding P4,800.00: The Court found that Dr. Coronado's earnings exceeding P4,800.00 per annum do not exclude him from the Compensation Act's coverage. While Section 39(e) defines "public employment" to exclude those paid more than P4,800.00 per annum, Dr. Coronado's claim is based on Section 3 of the Act, which does not impose such a limitation on earnings for covered employees. On the closure of the trial: The Court found no error or abuse of discretion in the hearing officer's action to close the trial. The records showed that NASSCO had secured at least four postponements. Despite a warning that no further postponements would be allowed, NASSCO's counsel again requested a postponement via telegram, which was denied upon proper objection. The Court emphasized that being a government-controlled corporation does not grant NASSCO the right to indefinitely delay trial. On the sufficiency of evidence: The Court held that the decision was supported by substantial evidence. The ruling was predicated on the uncontradicted testimony of Dr. Alipio Villacorta, a specialist, who stated that the claimant's ailment could have been caused by abrupt changes in atmospheric pressure during an airplane flight. This testimony, supported by certifications from other specialists, constituted substantial evidence. Even if hypertension was a contributing factor, it did not relieve the employer of responsibility, as aggravation of a preexisting disease due to working conditions entitles the claimant to compensation. The Court reiterated that the burden is on the employer to prove that the injury was not caused by the employment conditions, due to the statutory presumption of compensability.
Main Doctrine
A company physician engaged by a government-controlled corporation is considered an employee covered by the Workmen's Compensation Act, regardless of whether their duties involve manual labor or if their annual earnings exceed P4,800.00, provided the claim is not based on 'public employment' as defined in Section 39(e) of the Act. The employer bears the burden of proving that the injury or disease was not caused by the nature or conditions of employment.