Manila Electric Company v. Workmen Compensation Commission
REITERATIONFacts
The Antecedents: Fortunato Salameda was employed by Manila Electric Company (Meralco) from 1959 until his death on June 30, 1966. His roles progressed from laborer to steelman, and finally to boiler maker. In 1964, he began experiencing symptoms such as reddish eyes and nosebleeds, attributed by a physician to the heat from his welding job. Despite this, he returned to work and subsequently suffered from worsening headaches, loss of appetite, and vomiting. On May 14, 1966, he took sick leave due to severe head pain. Meralco denied his sister's plea for hospitalization, providing only medicine. Three days later, his condition deteriorated with abdominal pains, vomiting, severe headache, and blurred vision, leading Meralco to hospitalize him at its own hospital. There, he was diagnosed with a "cerebral brain tumor." He died before he could undergo surgery. Procedural History: The claimant, Lilia Vda. de Salameda, filed a death claim for herself and her minor children, seeking death compensation, burial expenses, and reimbursement of medical expenses. Meralco had previously filed an employer's report of accident or sickness, controverting any claim for compensation. The Commission's Acting Referee dismissed the claim. However, upon appeal, the Workmen's Compensation Commission reversed the referee's decision, finding the claim compensable and awarding disability compensation, death compensation, burial expenses, and attorney's fees. The Petition: Meralco filed a petition for review, questioning the Commission's findings on the nature of the deceased's work, the compensability of the brain tumor due to aggravation, the extinguishment of disability benefits upon death, and the award of attorney's fees.
Issue(s)
Whether the brain tumor which caused the death of the employee was aggravated by the nature of his work. Whether death foreclosed the right to disability benefits during illness. Whether the Commission can award attorney's fees to claimants' counsel motu propio.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, holding the illness compensable and the awards valid.
Ratio Decidendi
On the aggravation of illness: The Court found substantial evidence supporting the Commission's findings regarding the nature of the deceased's work, which involved physical exertion such as lifting steel, rigging boiler materials, operating machinery, and welding. While a brain tumor is not an occupational disease, the Court held that the deceased's work must have aggravated his illness. The progressive worsening of his condition from 1964 until his death in 1966, during which he continued to perform physically demanding jobs, led the Court to presume aggravation as a consequence of his work. The Court cited precedents where illnesses, even if not inherently occupational, were deemed compensable due to aggravation by work-related factors like continuous exertion or irregular hours. On the extinguishment of disability benefits upon death: The Court rejected Meralco's theory that disability benefits accrued to an employee are extinguished upon his death. It reasoned that such benefits represent lost or impaired earnings that the employer is liable to reimburse. The right to these benefits, having arisen during the employee's lifetime, is transmissible to his heirs, similar to uncollected salaries. The Court also noted that the award for temporary total disability was made in conjunction with death compensation, with the disability period being deducted from the total period for death benefits, rendering the issue of extinguishment academic in this specific case. On the award of attorney's fees: The Court affirmed the Commission's award of attorney's fees, citing Section 31 of the Workmen's Compensation Act, as amended by Republic Act No. 4119. The amendment explicitly states that attorney's fees are chargeable against the employer and are an integral part of the compensation due. Therefore, a specific prayer for attorney's fees and proof thereof are no longer necessary, and the Commission can award them motu propio. The Court distinguished this from prior rulings that applied before the amendment.
Main Doctrine
The aggravation of an employee's illness due to the nature of his work is presumed under circumstances where the illness progressively worsened during the period of employment involving physical labor, even if the illness is not occupational in nature. Disability benefits accrued to an employee prior to death are transmissible to his heirs.