Pangasinan Transportation Company v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Arturo Dacoycoy, employed by Pangasinan Transportation Company since 1947, initially as a painter and later as a gasoline man, developed pulmonary tuberculosis. His duties as a gasoline man involved delivering gasoline and oil in drums, which required him to unload and roll heavy containers. Medical examinations in 1954 and 1955 revealed progressive lung conditions, including tuberculosis and fibrosis. Despite his illness, the company allowed him to continue working, even returning him to his gasoline man duties after a period of light assignment, which likely aggravated his condition. He also suffered an accident in 1960, being pinned between a truck and a forklift, resulting in spitting blood. Procedural History: Dacoycoy filed a claim for compensation on March 12, 1963. The company initially intended to controvert the claim. An Acting Referee dismissed the claim twice: first, for being filed beyond the statutory period, and second, for insufficient evidence of compensability. The claimant appealed these orders. Subsequently, the claimant filed a notice to withdraw his claim, which was forwarded to the Workmen's Compensation Commission (WCC). Despite this withdrawal, the WCC proceeded to render a decision on December 23, 1965, awarding compensation to Dacoycoy. The company's motion for reconsideration was denied. The WCC, in its resolution, noted that the claimant had repudiated his withdrawal of claim. The Petition: Pangasinan Transportation Company filed a petition for review with the Supreme Court, challenging the WCC's decision. The company argued that the WCC erred in not remanding the case to determine the consideration for the withdrawal of claim, in not holding the claim was filed beyond the reglementary period, and in deeming the claim compensable contrary to the evidence. The Court addressed the withdrawal, noting that any settlement agreement requires approval by the WCC, which was not obtained, rendering the withdrawal invalid. It also found that the employer had knowledge of the claimant's illness, thus overcoming the delay in filing the claim. Finally, the Court affirmed the WCC's findings on compensability, based on substantial evidence that the claimant's employment contributed to the aggravation of his illness.
Issue(s)
Whether the withdrawal of the claim, purportedly due to an amicable settlement, was valid. Whether the claim was filed beyond the reglementary period prescribed by the Workmen's Compensation Act. Whether the claimant's illness was compensable.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, holding that the withdrawal of the claim was invalid and that the illness was compensable. The Court ordered the petitioner to pay the claimant compensation, medical services, and attorney's fees.
Ratio Decidendi
On the validity of the withdrawal of the claim: The Court held that the withdrawal of the claim, purportedly based on an amicable settlement, was invalid. Section 29 of Act 3428 requires that any agreement concerning compensation must provide at least the amount prescribed by the Act and must be approved by the Workmen's Compensation Commissioner or his authorized representative. Even if an agreement on the amount was reached, it was not approved by the Commissioner. Furthermore, the claimant had already repudiated his withdrawal of claim. Therefore, there was no necessity to remand the case to determine the consideration for the withdrawal. On the timeliness of the claim filing: The Court reiterated that failure to comply with the notice and filing requirements of Section 24 of the Workmen's Compensation Act is non-jurisdictional. Such failure does not bar proceedings if the employer had knowledge of the injury or sickness, or if the employer did not suffer by the delay. In this case, the employer had knowledge of the claimant's sickness as he availed of the company hospital facilities when hospitalized for pulmonary tuberculosis. Thus, the employer had knowledge of the sickness. On the compensability of the claim: The Court found the claim to be compensable, affirming the WCC's findings. The WCC noted that the respondent knew of the claimant's illness since 1954 but allowed him to continue working, which aggravated his condition. He was later given a light job but then returned to his old position, further aggravating his illness to the point of hospitalization and subsequent dismissal. The Court stated that it did not need to rely on the statutory presumption of compensability because the facts clearly showed that the claimant's employment contributed to the aggravation of his illness. The certification of fitness for work was also disregarded as the company dismissed him due to his illness.
Main Doctrine
An amicable settlement leading to the withdrawal of a claim for compensation under the Workmen's Compensation Act is invalid if not approved by the Workmen's Compensation Commissioner or his authorized representative, and failure to file a claim within the prescribed period is non-jurisdictional if the employer had knowledge of the sickness or was not prejudiced by the delay.