Tenasas v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Petitioner Mansueto D. Tenasas, employed as a stevedore by Delgado Brothers, Inc., contracted Pulmonary Tuberculosis in 1971 during his employment. He had previously received disability compensation for this ailment from April 23, 1971, to December 8, 1971. He resumed work in 1972, but his condition worsened, leading him to stop working on September 4, 1973, due to his ongoing illness and the strenuous nature of his job. 2. Procedural History: An Acting Referee of Regional Office No. IV rendered an award in favor of petitioner Tenasas on July 29, 1975, ordering Delgado Brothers, Inc. to pay disability compensation and attorney's fees. However, upon appeal by Delgado Brothers, Inc., the Workmen's Compensation Commission set aside this award, finding no sufficient proof that Tenasas was incapacitated to work when he stopped in September 1973 and concluding that medical evidence indicated his ailment was cured. 3. The Petition: Petitioner Mansueto D. Tenasas seeks review of the Workmen's Compensation Commission's decision. He argues that despite the Commission's findings, the evidence demonstrates he was still suffering from Pulmonary Tuberculosis when he ceased working and that his earning capacity was impaired, rendering him unable to perform his usual work as a stevedore. The Supreme Court is asked to reinstate the Acting Referee's award.
Issue(s)
Whether petitioner Mansueto D. Tenasas was incapacitated for his usual work as a stevedore due to Pulmonary Tuberculosis when he stopped working on September 4, 1973. Whether the medical reports presented by the respondent Commission sufficiently negated the claimant's alleged disability.
Ruling
The Supreme Court set aside the decision of the respondent Commission and reinstated the Acting Referee's award in favor of petitioner-claimant Mansueto Tenasas. The Court found that petitioner was indeed suffering from Pulmonary Tuberculosis when he returned to work in 1972 and continued to suffer from it, impairing his ability to perform his usual strenuous work as a stevedore, even if he could technically perform some work.
Ratio Decidendi
On Issue 1: The Supreme Court found that petitioner Mansueto D. Tenasas was indeed suffering from Pulmonary Tuberculosis when he returned to work in 1972, a fact known to the employer. Medical testimony from Dr. Ruben Nepomuceno confirmed that Tenasas was admitted as a "TB patient" in September 1972 with "minimal" PTB, which could be cured within six months to two years with proper medication. Further examination in February 1973 revealed "PTB minimal bronchial chronic still active." Although Dr. Nepomuceno stated Tenasas could resume work "with some risk," the Court considered his sporadic work schedule in 1973 (working only one day a month in July, five days in August, and the last day on September 4, 1973) as confirmation of his poor health and inability to handle the usual burden and strain of manual labor. The Court emphasized that the physical strain of his work as a stevedore, involving loading and unloading heavy cargoes, exacerbated his condition and led to his eventual cessation of work, coupled with reported "back pain." On Issue 2: The Supreme Court disagreed with the respondent Commission's conclusion that medical proofs negated the claimant's alleged disability. While acknowledging that petitioner might have been considered cured by July 1975, the Court stressed that the critical period was when he stopped working on September 5, 1973. The Court found that the employer assumed a risk by re-admitting Tenasas to work without a thorough medical examination to ascertain his fitness. The medical evidence, particularly the testimony of Dr. Nepomuceno regarding the active but minimal and chronic nature of the PTB in February 1973, supported the claim of ongoing illness. The Court cited the principle that disability need not be total; impairment of earning capacity for the usual work is sufficient. Therefore, the medical reports, when viewed in light of the claimant's continued symptoms and inability to perform his strenuous duties, did not conclusively negate his disability for his accustomed labor.
Main Doctrine
The Supreme Court reiterated that for an employee to be entitled to disability compensation under the Workmen's Compensation Act, it is not a prerequisite that they be totally and absolutely disabled to perform any kind of work. It is sufficient that the employee is rendered incapacitated for the usual work they are accustomed and competent to do, and as a consequence, their earning capacity is impaired. This doctrine emphasizes the liberal construction of labor laws in favor of the workingman.