Alatco Transportation, Inc. v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Pio Rosales was employed by Alatco Transportation, Inc. as a bus driver from 1949 to 1964. He underwent a pre-employment physical that found him healthy. Initially earning P120-P135 monthly, he transitioned to a commission basis in 1955, earning approximately P280-P300 per month. On October 15, 1964, Rosales filed a compensation claim alleging that his continuous work as a driver, with its associated strain and fatigue, led to him contracting pulmonary tuberculosis and other ailments. The company physician's report supported the claim, attributing the illness to the nature of his work and recommending a desk job. Procedural History: Following Rosales's claim, the petitioner, Alatco Transportation, Inc., filed a report disclaiming knowledge of the claimant's condition on the date of the claim. A hearing was held, and on July 31, 1966, Referee Estanislao D. Sarto ruled in favor of the claimant, ordering the petitioner to pay compensation, weekly benefits, medical services, and attorney's fees. The petitioner's motion for reconsideration was denied, and the case was forwarded to the Workmen's Compensation Commission. On July 13, 1967, the Commission affirmed the referee's decision, increasing the compensation amount and weekly benefits, and continuing medical services. The Commission en banc denied the petitioner's subsequent motion for reconsideration on February 5, 1969. The Petition: The petitioner filed a petition for certiorari on March 7, 1969, challenging the Commission's decision regarding the compensability of Rosales's pulmonary tuberculosis and the award of disability and medical benefits. The petitioner argued that the claimant was no longer suffering from the illness when he filed the claim and that his work did not aggravate it. The petitioner also contested the award of weekly compensation after the claimant's separation from service, asserting the termination of the employer-employee relationship. Furthermore, the petitioner questioned the order for continued medical services. The Supreme Court modified the decision, reducing the disability compensation, recalculating attorney's fees and administrative costs, and remanding the case to the Commission to determine the claimant's medical expenses.
Issue(s)
Whether the claimant's pulmonary tuberculosis was contracted in the course of and arose out of his employment, or was aggravated by his work. Whether the petitioner is liable for disability compensation after the claimant's separation from service. Whether the petitioner is liable for further medical services, appliances, and supplies despite the cessation of the employer-employee relationship.
Ruling
The Supreme Court modified the decision of the respondent Commission. The petitioner was ordered to pay the heirs of the claimant P1,820 as disability compensation, P182 as attorney's fees, and P23 as administrative costs and cost of review. The case was remanded to the Commission for determination of the amount advanced by the claimant for medical attendance and supplies from October 1, 1964, which the petitioner is to reimburse.
Ratio Decidendi
On the compensability of the illness: The Court affirmed the findings of the Commission that the claimant's pulmonary tuberculosis was contracted in the course of his employment or was the result of the nature of such employment. The Court held that the symptoms disappeared during confinement and returned when on duty, indicating that the sickness was a result of or aggravated by his employment as a driver. The Court emphasized that findings of fact by the Commission are binding unless unsupported by substantial evidence or there is a patent failure to evaluate evidence properly. The petitioner's argument that the claimant was no longer suffering from active tuberculosis when he filed the claim was refuted by the Commission's findings that the petitioner knew of the illness prior to the claim and that the claimant stopped working due to his illness and sought financial aid for hospitalization, indicating the persistence of the affliction. On disability compensation: The Court modified the award of disability compensation. It held that disability compensation represents lost or impaired earnings and becomes due from the time earning power is lost or impaired. The petitioner's liability for disability compensation accrued on September 6, 1964, when the claimant's illness compelled him to stop working and impaired his earning capacity, and subsisted only until June 16, 1965, when the employer-employee relationship ceased. The Court recalculated the disability compensation to P1,820, based on the period from September 6, 1964, to June 16, 1965, and found no basis for compensation after the termination of employment. On medical services: The Court reiterated that the employer's liability to provide medical attendance and hospital services subsists during the entire period of the employee's disability, even after the cessation of the employer-employee relationship, provided the illness was contracted during employment or aggravated by work. This obligation lasts until the arrest of the illness. The Court noted that Section 13 of the Workmen's Compensation Act does not provide a maximum amount or time limit for medical expenses, requiring the employer to furnish services as the nature of the disability and recovery may require. Due to the supervening death of the claimant, the case was remanded to the Commission to determine the expenses advanced by the claimant for medical attendance and supplies from October 1, 1964, until his death, which the petitioner must reimburse.
Main Doctrine
The employer's liability to provide medical services and supplies to an employee suffering from a work-connected illness subsists during the entire period of the employee's disability, notwithstanding the cessation of the employer-employee relationship, until the illness is arrested.