Manila Pest Control v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Mario Abitria, an employee of Manila Pest Control, Inc., filed a claim for compensation benefits due to a debilitating illness, pulmonary tuberculosis, which he alleged was contracted in the course of his employment. The claimant testified and presented a physician's diagnosis supporting his claim. Procedural History: The Workmen's Compensation Commission (WCC), through its referee, considered the complaint for decision after the claimant and physician testified, as petitioner's counsel failed to appear at the hearing. Petitioner's motion for reconsideration, seeking to present evidence and cross-examine witnesses, was denied, as a decision had already been rendered awarding Abitria P6,000.00. A subsequent motion for reconsideration, alleging lack of notice of the decision, was also denied. A writ of execution was granted, and the City Sheriff levied on petitioner's properties. The Petition: Manila Pest Control, Inc. filed a petition for certiorari and prohibition with a plea for preliminary injunction, alleging that the WCC acted with grave abuse of discretion or in excess of jurisdiction by denying them procedural due process. They sought to annul the writ of execution and all related proceedings.
Issue(s)
Whether the petitioner was denied procedural due process. Whether the illness of respondent Mario Abitria was service-connected and compensable under the Workmen's Compensation Law.
Ruling
The petition for certiorari and prohibition was denied. The writ of execution and all proceedings in RO4-WC Case No. 5503 were upheld. Treble costs were imposed against petitioner, to be paid by its counsel, Attorney Manuel A. Corpuz.
Ratio Decidendi
On Issue 1: The Court held that petitioner was not denied procedural due process. The alleged failure to receive a copy of the decision was attributed to the conduct of petitioner's own counsel, Attorney Manuel A. Corpuz. The employee of the WCC attempted to serve the decision on Attorney Corpuz, who refused to accept it, instructing the employee to deliver it to Attorney Camacho, who he claimed was now handling the case. The decision was then served on Attorney Camacho's office. The Court found the explanation in the affidavit of the WCC employee to be more credible than the rejoinder filed by petitioner's counsel, noting that counsel's actions appeared to be an attempt to delay or evade liability. The Court emphasized that the concept of due process, intended to ensure justice, should not be perverted to visit injustice upon a litigant. On Issue 2: The Court affirmed the findings of the Workmen's Compensation Commission that respondent Mario Abitria's illness, pulmonary tuberculosis, was service-connected and compensable. The Commission found substantial evidence that Abitria contracted the illness due to his work as a laborer, which involved strenuous physical exertion, exposure to chemical fumes, and lowered resistance. The attending physician testified that the nature of claimant's work aggravated his condition. The Court noted that there was no evidence that Abitria was sick upon entering employment, creating a presumption that he was normal at the start. The respondent employer failed to dispute the work connection or show that the ailment was due to causes other than the nature of his work. The Court concluded that the illness was service-connected, and the employer was liable for compensation.
Main Doctrine
The Supreme Court reiterated that a claim of denial of procedural due process is unavailing when the alleged procedural defect arises from the actions or instructions of the petitioner's own counsel, particularly when such actions lead to the failure to receive notice or present evidence. Furthermore, the Court emphasized that factual findings of administrative bodies, such as the Workmen's Compensation Commission, are generally considered conclusive and binding on the Supreme Court if supported by substantial evidence, and will not be disturbed absent a showing of grave abuse of discretion, fraud, or error of law.