Delgado Brothers v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Ignacio Fernandez, a rigger employed by Delgado Brothers, Inc., became dizzy while loading concrete products onto a trailer on September 17, 1967. He was advised to go home, collapsed upon arrival, and died the following day from cerebro-vascular hemorrhage. His widow, Esperidiona Vda. de Fernandez, filed a claim for compensation on behalf of herself and their minor son, Ruben Fernandez. 2. Procedural History: The widow filed a notice and claim for compensation with the Department of Labor. Although the employer's insurance carrier filed an Employer's Report of Accident or Sickness, it controverted the claim without stating a reason. An award was subsequently made by the Acting Chief Referee, holding the claim compensable based on the employer's report and physician's statement. The employer's motion for reconsideration was denied, as was an appeal to the Workmen's Compensation Commission. The Commission's Chairman affirmed the award, and a subsequent motion for reconsideration by the Commission en banc was also denied, leading to the present appeal. 3. The Petition: This case is before the Supreme Court on appeal by certiorari. The petitioner, Delgado Brothers, Inc., argues that the award was issued summarily despite a timely controversion of the claim. The petitioner's main contention is that the Employer's Report of Accident or Sickness did not contain admissions supporting the award and that there was no proof of dependency. The Court notes that the Employer's Report did contain information about the nature of the work, the circumstances of the illness, and the names of dependents, and that the petitioner did not present evidence to rebut the presumption that the illness was service-connected.
Issue(s)
Whether the summary award issued by the Referee was valid despite the petitioner's general controversion of the claim. Whether the decedent's death from cerebro-vascular hemorrhage is compensable under the Workmen's Compensation Act.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, holding that the claim for compensation is compensable. The Court ordered the petitioner to pay the claimants the total sum of P5,400.00 as compensation and reimbursement of burial expenses, plus P53.00 as attorney's fees to the Office.
Ratio Decidendi
On Issue 1: The Court ruled that the summary award was valid because the petitioner's motion for reconsideration failed to demonstrate a meritorious defense. The Employer's Report of Accident or Sickness explicitly stated that the employee was 'lashing concrete products being loaded onto trailer' when the illness manifested, which constitutes a factual admission of work-related activity. Petitioner failed to specify any evidence to rebut the connection between the nature of the work and the cerebral hemorrhage. Furthermore, the petitioner's claim regarding the lack of proof of dependency was contradicted by the list of dependents included in its own report and the widow's affidavit of dependency. The absence of an affidavit of merits showing a good defense further justified the summary nature of the proceedings. Consequently, the admissions in the employer's report overcame the unsupported general controversion. On Issue 2: The Court held that the death is compensable by applying the legal presumption that an illness supervening in the course of employment arises out of it. Since Fernandez experienced dizziness while performing heavy labor as a rigger, the burden shifted to Delgado Brothers, Inc. to prove that the illness was not service-connected. Under the doctrine established in Vargas v. Philippine American Embroideries, Inc. and related jurisprudence, the lack of evidence to offset this presumption renders the claim valid. The Physician's Report also noted that the cerebral hemorrhage resulted from the nature of the worker's employment. Therefore, in the absence of substantial evidence to the contrary from the employer, the presumption of compensability remains absolute. The court affirmed that the rigger's duties directly preceded his collapse and ultimate demise.
Main Doctrine
The Employer's Report of Accident or Sickness, which admits that the employee became ill while in the actual performance of his duties and that the illness (cerebral hemorrhage) was the result of the nature of his work, overcomes any controversion filed by the employer or its insurance carrier, establishing the compensability of the claim. Furthermore, an illness contracted during the performance of duties is presumed to be service-connected, and this presumption stands unless rebutted by substantial evidence.