Limos v. Fernandez Hermanos
REITERATIONFacts
The Antecedents: Claimant Mariano Limos was employed by respondent Fernandez Hermanos, Inc. as Manager-Veterinarian on October 16, 1952. On June 2, 1961, he was diagnosed with PTB, moderately advanced, active (bilateral), and was treated by company physicians. Despite his illness, he continued working until October 1, 1972, when he resigned after 20 years of service, receiving P15,000.00 as retirement pay and signing a 'Release of Claim'. He filed a claim for disability benefits and medical expenses on March 31, 1975, for the illness he contracted in 1961 and by reason of which he stopped working in 1972. Procedural History: The Acting Referee of Regional Office No. 4, Department of Labor, granted an award for disability compensation and medical expenses. However, the Workmen's Compensation Commission set aside the award, absolving the employer on the grounds that the claimant continued to work, received his salary, was not disabled, and voluntarily resigned, with his x-ray showing PTB only two years after resignation. The Petition: Mariano Limos sought a review of the decision of the Workmen's Compensation Commission.
Issue(s)
Whether the 'Release of Claim' signed by the petitioner bars his claim for disability compensation under the Workmen's Compensation Act. Whether the petitioner's pulmonary tuberculosis was contracted in the course of and by reason of his employment. Whether the petitioner's resignation was voluntary and not precipitated by his illness.
Ruling
The Supreme Court set aside the decision of the respondent Commission and reinstated the Referee's award. The employer was ordered to pay the claimant the maximum compensation benefit of P6,000.00, P1,329.00 for medical expenses, P300.00 as attorney's fees, and P61.00 to the Workmen's Compensation Fund. Additionally, the employer was mandated to furnish the claimant with necessary services and supplies for his recovery and pay an additional P300.00 for attorney's fees on appeal.
Ratio Decidendi
On the effect of the 'Release of Claim': The Court held that the 'Release of Claim' document, though worded broadly, did not expressly include compensation for illness contracted in the course of employment and the resulting disability. The P15,000.00 paid was considered separation or retirement pay, a gratuity for faithful service. In the absence of an express provision waiving compensation for work-related illness, the employer cannot evade liability under the Workmen's Compensation Act. Section 7 of the Act explicitly prohibits any contract, regulation, or device intended to exempt the employer from liability, as the protection of the workman's welfare is a matter of public policy. Therefore, the 'Release of Claim' was given no valid effect in discharging the employer's liability. On whether pulmonary tuberculosis was contracted in the course of employment: The Court found that the evidence indisputably showed that Mariano Limos was in good health upon employment and that his work as manager-veterinarian on an isolated island for twenty years, coupled with his developing debility and fatigue, led to his diagnosis of PTB. The company physician was aware of his condition. The continued work despite illness and the active nature of the tuberculosis as shown in later x-rays indicated that the ailment was incurred during his employment. The Commission's conclusion that the PTB occurred only after resignation was deemed preposterous, ignoring the undisputed history of the sickness known to the company. On whether the resignation was voluntary and not precipitated by illness: The Court disagreed with the Commission's conclusion that the resignation was voluntary and not due to illness. It found that the stark reality was that twenty years of hard labor and a serious ailment had converted Limos into a physical wreck. Even if he voluntarily resigned, his pulmonary tuberculosis was the major factor that precipitated the resignation. The Court reasoned that it is unlikely for an employer to hire a tuberculous individual, implying that the illness rendered him less employable and thus a factor in his departure.
Main Doctrine
A 'Release of Claim' executed by an employee in favor of an employer, even if worded broadly and accompanied by payment of separation or retirement pay, cannot validly exempt the employer from liability for compensation under the Workmen's Compensation Act if it does not expressly include compensation for illness contracted in the course of employment and the resulting disability. Such a waiver is void as against public policy, as it circumvents legislative measures designed to protect the welfare of the workingman.