Veloso v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Francisco Veloso, employed as a platero from 1961 to December 14, 1971, sought compensation for a lung ailment he contracted during his employment. Despite being treated for the ailment, he continued working. His chest X-ray on September 9, 1971, revealed minimal infiltration, predominantly fibrotic. He voluntarily resigned on December 14, 1971. Procedural History: Veloso filed a claim for compensation on September 26, 1972, with the Regional Office No. 4 of the Department of Labor. The Regional Office found his illness to be work-related but denied the claim due to the filing occurring after his employment ceased. The Workmen's Compensation Commission affirmed this decision, reasoning that his resignation was voluntary and that his X-ray findings suggested a healed lesion, contradicting his claim of illness at the time of resignation. The Petition: This case is before the Supreme Court on a petition for certiorari to review the decision of the Workmen's Compensation Commission. The petitioner argues that his illness was directly caused or aggravated by his employment and that the claim's filing after separation from service is not a fatal defect, as the compensation claim is a statutory liability with a ten-year prescription period. He further contends that his resignation was not voluntary but a result of his weakened condition due to illness, preventing him from continuing gainful employment.
Issue(s)
Whether the claim for compensation is compensable under the Workmen's Compensation Act. Whether the filing of the claim after the cessation of the employer-employee relation is a fatal defect barring compensation. Whether the claimant's resignation was voluntary or induced by his illness.
Ruling
The decision of the respondent Workmen's Compensation Commission is reversed and set aside. Respondent La Elegancia Jewelry is ordered to pay claimant Francisco Veloso P6,000.00 as liability compensation, medical and hospital expenses, attorney's fees equivalent to 10% of the recoverable amount, and P61.00 as administrative fee, with costs against the private respondent.
Ratio Decidendi
On whether the claim is compensable: The Court affirmed the findings of the Acting Referee of Regional Office No. 4 that the claimant's illness was directly caused or aggravated by the nature of his work with the respondent. This satisfies the requirement under Section 2 of the Workmen's Compensation Act, which allows compensation for illnesses contracted due to employment or aggravated by the nature of such employment. The Court cited Tecla Magpantay, etc., et al. vs. WCC, et al. to support this principle, emphasizing that the direct causation or aggravation by employment is the crucial factor for compensability. On the effect of filing after cessation of employment: The Court held that filing the claim after separation from service is not a fatal defect that deprives the Workmen's Compensation Commission of jurisdiction. The compensation under the Act is a statutory liability that prescribes in ten years, pursuant to Article 1144(2) of the Civil Code. This rule is particularly applicable when, as in this case, there is no showing that the employer sustained damage due to the delayed filing. The Court relied on the ruling in Domingo Vallo vs. WCC, et al. to underscore the ten-year prescriptive period for such claims. On the nature of the resignation: The Court agreed with the claimant that he was asked to resign because he was too weak to work, inferring that this was the reason for his resignation. The fact that he did not engage in any other employment after resigning further evidenced his inability to be gainfully employed due to his condition. This finding contradicted the Commission's conclusion that the resignation was voluntary and that the X-ray findings indicated a healed lesion, thereby undermining the claimant's allegations of illness.
Main Doctrine
A claim for compensation under the Workmen's Compensation Act is not rendered fatally defective by being filed after the cessation of the employer-employee relation, as such statutory liability prescribes in ten years, especially when the employer sustains no damage from the delayed filing.