Lombo v. Standard Cigarette Manufacturing
REITERATIONFacts
1. The Antecedents: Pascuala Lombo, a laborer for Standard Cigarette Manufacturing Co. from 1951 to June 5, 1967, filed a claim for compensation. She alleged that she contracted Pulmonary Tuberculosis (PTB), heart disease, and high blood pressure in the course of her employment, which began to manifest in 1965 and were aggravated by her work conditions. She sought compensation for medical expenses and disability. 2. Procedural History: Lombo filed her claim with the Department of Labor's Regional Office No. 4. After trial, the Hearing Officer dismissed the claim on January 17, 1969, finding that Lombo failed to prove her ailments were caused or aggravated by her employment and that she was not disabled. A motion for reconsideration was denied on April 27, 1972. The Workmen's Compensation Commission en banc subsequently denied a further motion for reconsideration on May 31, 1972, leading to the present petition for review. 3. The Petition: Lombo petitions this Court for a review of the Commission's decision, arguing that the Commission erred in several respects. Specifically, she contends the Commission failed to give effect to Sections 45, 37, and 44 of Act 3428 (as amended) regarding timely controversion, employer's report, and presumption of compensability. She also argues the Commission erred in disregarding the presumption of compensability for illnesses arising during employment, giving undue credence to the company's claims of her resignation due to lost cigarette labels, and failing to find her illnesses compensable and aggravated by her work, despite the benevolent provisions of the Act favoring claimants.
Issue(s)
Whether the Workmen's Compensation Commission erred in failing to find that the respondent company failed to reasonably controvert the claim and comply with its reportorial duty under Sections 45 and 37 of Act No. 3428, as amended. Whether the Workmen's Compensation Commission erred in not applying the presumption of compensability under Section 44 of Act No. 3428, as amended, to the claimant's illness. Whether the claimant's illness (Pulmonary Tuberculosis Minimal and Hypertension) was contracted in the course of her employment or aggravated thereby, thus making it compensable under the Workmen's Compensation Act. Whether the Workmen's Compensation Commission erred in giving credence to the respondent company's contentions regarding the claimant's separation from employment.
Ruling
The Supreme Court affirmed the decision and resolution of the Workmen's Compensation Commission denying compensation to the petitioner. Costs were against the petitioner.
Ratio Decidendi
On Issue 1: The Court found that the respondent company did in fact controvert the claim by filing its answer in due time after an extension had been granted, which is considered a sufficient controversion as held in Evans v. WCC. There was no evidence that the claimant's alleged illness reached the knowledge of the management before the claim for compensation was filed and controverted. The medical certificates presented were deemed irrelevant as the illness was never conveyed to the company, nor did the company gain knowledge of it since the claimant was not absent from work due to illness and stopped working only after the investigation of the lost Ben Hur labels. Consequently, the employer was not obligated to submit a report under Section 37 of the Act until it gained knowledge of the disability, which the claimant never provided through the notice required by Section 24. Furthermore, the issue of non-controversion was raised for the first time in the motion for reconsideration en banc, a defense that should have been pleaded earlier, hence deemed waived as per Rebodos v. WCC. The first assigned error was therefore found to be without basis. On Issue 2: The Court acknowledged the benevolent provisions and presumptions under Section 44 of the Workmen's Compensation Act but found these considerations unavailing in light of the evidence presented. The principle that workmen's compensation is based on incapacity or disability for work and the loss or impairment of earning capacity was reiterated, citing Central Azucarera Don Pedro v. De Leon. As long as an employee is able to work and receives pay, even if suffering from an illness, they are not entitled to compensation. The claimant in this case never incurred a loss of earning power as she stopped working and then immediately worked with another company, as evidenced by a certificate of employment. Therefore, the presumptions in Section 44, while generally favorable to claimants, could not overcome the factual findings that the claimant did not suffer a compensable disability resulting in loss of earning capacity related to her employment. On Issue 3: The Court held that the claimant's illness did not fall within the ambit of the Workmen's Compensation Act. It cited Pampanga Sugar Development Co. Inc. v. Quiroz, which elucidated that an injury is received "in the course of" employment when it occurs while performing duty, and "arises out of" employment when there is a causal connection between working conditions and the injury. The causative danger must be peculiar to the work and incidental to the business, not a common hazard or independent of the master-servant relation. The Court noted that the claimant's work as a "poucher" was demonstrated to be light, and she herself described the working conditions as acceptable with windows, electric fans, tables, and chairs. Her claim that her illness arose out of her work or was aggravated by it was not substantiated by evidence. The liberal rules of interpretation for the Act are not applicable when facts clearly show the sickness is not compensable, as the Hearing Officer's finding of a light job and no evidence of causation or aggravation was supported by substantial evidence. This factual finding, upheld by the Commission, was deemed binding upon the Supreme Court absent grave abuse of discretion, which was not shown. On Issue 4: The Commission's decision to discredit the claimant's version of her separation from employment was upheld by the Supreme Court. The Commission noted glaring inconsistencies and contradictions in Lombo's testimony, particularly her initial assertion that she stopped due to illness and her later claim of being told to stop by the manager, as well as her false statement about not working elsewhere after June 5, 1967, which was directly refuted by a certification of employment from another company. These contradictions led the Commission to conclude that it could not give credence to the claimant's declarations. The Supreme Court consistently defers to factual findings of administrative bodies when supported by substantial evidence and absent grave abuse of discretion. The inconsistencies significantly undermined the claimant's credibility, making her account of why she left work unreliable, and thus the Commission's finding on this matter was sustained.
Main Doctrine
The claimant failed to establish that her illness was contracted or aggravated in the course of employment, and she also failed to prove loss of earning capacity, rendering her claim for compensation under the Workmen's Compensation Act non-compensable. Furthermore, the employer timely controverted the claim, and the claimant failed to provide timely notice of her illness.