Lorenzo v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Leopoldo Lorenzo, an employee of Philippine Glass Manufacturing Co., Inc. since February 1964, filed a claim for compensation benefits under the Workmen's Compensation Act. He alleged that he contracted a lung ailment, specifically Pulmonary Tuberculosis (PTB), during and in the course of his employment, which ultimately forced him to stop working on October 4, 1974. Lorenzo claimed to have orally notified the company's manager of his ailment on August 27, 1974. 2. Procedural History: The claim was initially dismissed by the Regional Office No. IV of the Department of Labor on October 2, 1975, for lack of merit, with the finding that Lorenzo had not suffered a disability prior to the company's cessation of operations. Lorenzo received this order on November 20, 1975. After his motion for reconsideration was denied, the case was elevated to the Workmen's Compensation Commission (WCC). The WCC affirmed the dismissal on December 31, 1975, despite acknowledging that Lorenzo contracted PTB on August 27, 1974, due to factors related to his employment, but ruled that the claim was not compensable due to a lack of competent medical evidence showing disability during his employment or at the time of separation. 3. The Petition: This petition seeks to reverse the WCC's decision. The petitioner argues that both lower bodies erred in not applying the legal presumption of compensability once the illness was found to have supervened during employment. He contends that the WCC's finding of no competent medical evidence is contrary to the record, citing physician's medical certificates and X-ray results that were never disputed by the employer. The petitioner further asserts that tuberculosis is not an instantaneous disease and that the medical evidence, even if taken after his cessation of work, demonstrates the illness was contracted during employment. Additionally, he argues that the company's closure of business on October 4, 1974, does not prejudice his right to compensation and that the company failed to timely controvert his claim, thereby waiving its right to raise non-jurisdictional defenses.
Issue(s)
Whether the illness of Pulmonary Tuberculosis (PTB) is compensable under the legal presumption of compensability when it manifests at the time of a business closure. Whether X-ray results and medical certificates issued shortly after the cessation of business operations constitute competent evidence of a disability incurred during employment. Whether the closure of the employer's business for lack of fuel supply exempts it from liability for compensation benefits that accrued prior to or at the time of closure. Whether the employer's failure to timely controvert the claim results in a waiver of non-jurisdictional defenses.
Ruling
The decision of the respondent Workmen's Compensation Commission is set aside. Respondent Philippine Glass Manufacturing Co., Inc. is ordered to pay petitioner Leopoldo Lorenzo disability benefits, reimburse medical expenses, and provide necessary services and appliances for his recovery. The costs are to be paid by the respondent company.
Ratio Decidendi
On Issue 1: The Court ruled that because the petitioner's illness supervened in the course of employment, the rebuttable presumption of compensability applies. Following established jurisprudence, once an illness is shown to have occurred during employment, it is presumed to have arisen out of or been aggravated by said employment. The burden of proof shifts to the employer to provide substantial evidence to the contrary. In this case, the respondent company failed to discharge this burden, and the Commission even explicitly found that the petitioner's PTB was due to fatigue and exposure to intense heat and fumes, yet inexplicably denied the claim. On Issue 2: The Court held that medical reports and X-ray results taken shortly after the work stoppage are competent evidence of the disease's existence during employment. Citing Valencia v. WCC, the Court emphasized that PTB is not an instantaneous disease; it is a chronic infection with an incubation period of two to ten weeks. Since the petitioner was found to have PTB only three days after the company closed, he could not have 'suddenly and instantaneously' contracted it in that interval. Under Section 49 of the Workmen's Compensation Act, a medical report from an attending physician may be received as evidence and used as proof of the facts in dispute. On Issue 3: The Court declared that the cessation of business operations does not prejudice an employee's right to compensation. Applying Ayuso v. WCC and Laude v. Cine Moderna, the Court ruled that an employer's liability under the Workmen's Compensation Act sets in the moment the employee becomes ill during employment. Subsequent closure of the business, whether due to lack of fuel, expiration of license, or destruction of property by fire, does not excuse the private respondent from the obligation to provide benefits to an employee who became disabled while the relationship existed. On Issue 4: The Court found that the respondent company failed to timely and effectively controvert the claim. The employer had knowledge of the illness as early as February 1974 via Social Security System (SSS) sickness notifications and again in August 1974, yet failed to file a notice of controversion within the periods prescribed by Sections 37 and 45 of the Act. This failure constitutes a renunciation of all non-jurisdictional defenses, including the non-compensability of the claim. The Commission committed a grave abuse of discretion by failing to treat the claim as uncontroverted.
Main Doctrine
The Supreme Court reiterated that once an illness is shown to have supervened in the course of employment, the presumption of compensability arises, placing the burden upon the employer to prove by substantial evidence that the illness is not work-related or aggravated. The Court also emphasized that medical evidence, such as X-ray findings, taken after the cessation of employment is competent to establish compensability for chronic diseases like tuberculosis, as the nature of such illnesses implies they were contracted during the period of employment. Furthermore, the failure of an employer to timely controvert a compensation claim constitutes a waiver of all non-jurisdictional defenses, including the defense of non-compensability.