Manila Railroad Company v. Rivera
REITERATIONFacts
The Antecedents: Respondent Mariano Rivera was employed by petitioner Manila Railroad Company as a laborer from December 1923 to January 1942. He was re-employed in 1958 as a trackman and later promoted to maintenance capataz. On January 13, 1961, a chest X-ray revealed respondent Rivera had moderate fibro-caseous infiltrates in his right upper lung field and fibroacinar infiltrates in his left lung, indicative of pulmonary tuberculosis. On June 8, 1961, petitioner informed Rivera he was disqualified for employment due to pulmonary tuberculosis and should stop working, which he did on June 16, 1961. His service was officially terminated on July 31, 1961. Procedural History: Respondent Rivera filed a notice of injury or sickness and claim for compensation on October 10, 1961. Petitioner filed its employer's report on November 10, 1961. The Hearing Officer ordered petitioner to pay compensation and medical expenses. The Workmen's Compensation Commission affirmed the decision, ordering lump sum and weekly compensation, reimbursement for medical expenses, and further medical services. Petitioner's motion for reconsideration was denied en banc. The Petition: Petitioner sought review, arguing that the illness must produce disability, the claim was filed out of time, and the award was not supported by evidence.
Issue(s)
Whether the claim for compensation was filed out of time and barred by the statute of limitations. Whether the award is based on findings contrary to, and not supported by, the evidence on record. Whether the medical expenses incurred by the claimant are compensable.
Ruling
The decision of the Workmen's Compensation Commission is affirmed with modification. The award for medical expenses not supported by receipts is disallowed.
Ratio Decidendi
On the issue of the claim being filed out of time: The Court held that the failure to file a notice of injury or sickness and claim for compensation within the prescribed period is non-jurisdictional. This failure does not bar proceedings if the employer had knowledge of the illness or sickness, or if the employer did not suffer by such delay. In this case, petitioner had knowledge of respondent's illness since January 1961 when the company physician confirmed it. Petitioner's failure to controvert the right to compensation within the statutory period was deemed a waiver of the right to controvert the claim. The Court cited previous rulings in Manila Railroad Co. vs. Workmen's Compensation Commission, et al., Rio y Compania vs. Workmen's Compensation Commission, et al., and National Development Co. vs. Workmen's Compensation Commission, et al. to support this position. On the issue of the award being unsupported by evidence: The Court reiterated its consistent ruling that findings of fact by the Workmen's Compensation Commission are binding upon the Supreme Court, provided there is substantial evidence to support them. The Commission's findings regarding the nature of respondent's work as a trackman and capataz, involving strain and exposure, were supported by evidence. The Court also noted that the Commission's interpretation of the X-ray findings as indicative of a moderately advanced stage of pulmonary tuberculosis was supported by the respondent's physician's statement that the claimant likely had the minimal stage three or four years prior. The Court concluded that the employment aggravated the ailment, especially considering the nature of the work and the physician's admission that further work could aggravate tuberculosis without treatment. The Court invoked the rebuttable presumption that an illness occurring during employment arose out of, or was aggravated by, such employment, and the burden to overthrow this presumption lies with the employer, which petitioner failed to do. On the issue of medical expenses: The Court disallowed the award for medical expenses in the amount of P110.00. It was admitted that these expenses were not supported by receipts, and there was no showing that the attending physician was presented at the hearing to substantiate the claim. Therefore, these expenses were not deemed compensable.
Main Doctrine
The failure to file a claim within the prescribed period is non-jurisdictional and does not bar proceedings if the employer had knowledge of the illness and did not suffer by the delay, especially when the employer failed to controvert the claim. Findings of fact by the Workmen's Compensation Commission are binding on the Supreme Court if supported by substantial evidence. The presumption that an illness arose out of or was aggravated by employment is rebuttable, with the burden of proof on the employer.