Landayan v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Rodrigo Landayan was employed as a carpenter by respondent Atlantic Gulf & Pacific Co. of Manila, Inc. (Company) in October 1966. In June 1968, the Company's physician, Dr. Bataclan, diagnosed petitioner as suffering from pulmonary tuberculosis. Petitioner's attending physician, Dr. Amadeo Jorge, further diagnosed him with moderately advanced, active pulmonary tuberculosis with cavity and bronchiectasis. Petitioner's employment was terminated on June 6, 1968, and he has been out of work since due to his ailment. Procedural History: On June 29, 1975, petitioner filed a claim for compensation, which was granted by Acting Labor Referee Vivencio Escarcha, ordering the Company to pay P6,000.00 in disability compensation and P61.00 as fee to the Office. On motion for reconsideration by the Company, the Workmen's Compensation Commission reversed the Acting Labor Referee's decision, dismissing the case for lack of merit due to the Physician's Report not being corroborated by laboratory findings or chest x-ray. The Petition: Petitioner seeks review of the Commission's decision, raising the sole issue of whether a Physician's Report is sufficient to support a claim under Act 3428, as amended.
Issue(s)
Whether a Physician's Report is sufficient to support a claim under Act 3428, as amended. Whether the respondent Company is estopped from denying the petitioner's illness.
Ruling
The decision of the respondent Commission is reversed and set aside, and the decision of the Acting Referee of Regional Office No. 4 is revived and reinstated, with the modification that the respondent Company shall also pay petitioner medical and hospital expenses duly receipted for until full recovery and to his lawyer the amount of P600.00 as attorney's fees.
Ratio Decidendi
On the sufficiency of the Physician's Report: The Court held that the Physician's Report does not require attached x-ray examinations or laboratory findings to be valid. The absence of such attachments does not invalidate the diagnosis contained therein. Furthermore, the Court reasoned that the attending physician's report, which included a diagnosis of "PULMONARY TUBERCULOSIS MODERATELY ADVANCED, ACTIVE WITH CAVITY BRONCHIECTASIS" and a "GUARDED" prognosis, logically infers that a previous x-ray examination must have been conducted for the physician to arrive at such a diagnosis. The Court emphasized that the illness being moderately advanced and active could be determined through physical examination, making x-ray or laboratory findings not indispensable. The Court cited the case of Rolando Flores vs. Workmen's Compensation Commission and Liberty Manufacturing Corp. to support its position. On the respondent Company's estoppel: The Court found that the respondent Company is estopped from denying the petitioner's illness because its own physician, Dr. Bataclan, was the first to find that the petitioner was suffering from pulmonary tuberculosis. This finding by the Company's physician was the immediate cause of the termination of the petitioner's services. Therefore, the Company cannot subsequently deny the existence of the illness it had previously acknowledged through its own medical representative. The Court also noted that the petitioner had complied with the requirements under Section 23 of the Workmen's Compensation Act, further supporting his claim for benefits.
Main Doctrine
A Physician's Report, even without attached laboratory findings or x-ray results, is sufficient to support a claim under the Workmen's Compensation Act, especially when corroborated by the employer's own physician's findings and the nature of the illness is readily determinable through physical examination.