Legaspi v. Province of Negros Occidental
REITERATIONFacts
The Antecedents: Petitioner Cresencio G. Legaspi, a nursing attendant at the Dona Corazon Locsin Montelibano Memorial Hospital, filed a claim for compensation under the Workmen's Compensation Act due to an illness diagnosed as Asthma. He alleged that his condition either supervened in the course of his employment or was aggravated by the working conditions, leading to temporary disabilities for work on two separate occasions in 1973. The respondent hospital controverted the claim, citing pre-existing asthma, the non-contagious and hereditary nature of the disease, its absence from the schedule of compensable disabilities, and the fact that petitioner was paid his full salary during his absences. Procedural History: The claim was initially filed with the Department of Labor, Sub-Regional Office No. VII, Bacolod City. A Referee granted the claim, ordering the hospital to provide medical services, pay compensation for a 48% non-scheduled disability (N.S.D.), and cover attorney's fees and administrative fees. The respondent hospital appealed this decision to the Workmen's Compensation Commission (WCC). The WCC, en banc, reversed the Referee's award and dismissed the claim, finding that the petitioner did not suffer a loss of earning power as he was paid his full salary during his absences and that asthma is not a disease subject to percentage rating for non-scheduled disability under Section 18 of the Act. The Petition: Petitioner Cresencio G. Legaspi seeks review of the WCC's decision, treating it as a special civil action. He argues that the Referee's award was based on Section 18 of the Workmen's Compensation Act and not solely on loss of earning capacity. The petition contends that his asthma was aggravated by his employment as a nursing attendant, citing his exposure to dust, germs, and bacteria in a hospital setting, including the contagious section. Despite the WCC's finding that asthma is not a scheduled disability and that he was paid his full salary, the petitioner seeks the reversal of the WCC's decision and the reinstatement of the Referee's award, asserting entitlement to disability benefits.
Issue(s)
Whether petitioner's asthma was work-aggravated and thus compensable under the Workmen's Compensation Act. Whether the petitioner is entitled to disability compensation despite having received his full salary during the periods of his temporary disability. Whether asthma can be classified as a non-scheduled disability under Section 18 of the Workmen's Compensation Act.
Ruling
The Supreme Court modified the decision of the Workmen's Compensation Commission. While the petitioner's asthma was found to have been aggravated by his employment, he was not entitled to disability compensation because he received his full salary during his absences, thus suffering no loss of earning capacity. However, the Court ordered the hospital to reimburse his medical expenses and furnish him with necessary medical services and appliances.
Ratio Decidendi
On Issue 1: The Court ruled that petitioner's asthma was indeed aggravated by his employment. It noted that the petitioner was incessantly exposed to dust, dirt, and bacteria while scrubbing hospital floors and caring for patients in the contagious section. Applying the principle of work-aggravation, the Court held that even if the asthma was a pre-existing hereditary or allergic disease, the hospital failed to prove that the work conditions did not contribute to its aggravation. The constant contact with infected patients and the physical demands of a nursing attendant's rotation tour of duty established a clear link between the illness and the employment. On Issue 2: The Court sustained the Workmen's Compensation Commission's finding that the petitioner is not entitled to disability compensation because there was no loss of earning capacity. Citing Corales v. ECC and GSIS, the Court emphasized that 'disability' under the Act refers to the loss or impairment of salary, not the physical injury itself. Since Legaspi was paid his full salary for the 16 days he was absent, he did not suffer any diminution of earning power. The Court clarified that medical disability without an accompanying decrease in earning capacity cannot trigger the payment of monetary disability benefits. On Issue 3: The Court held that asthma does not qualify as a non-scheduled disability under Section 18 of the Act. Section 18 specifically deals with amputations of hands and feet, disfigurement of the face or head, and other cases 'of this kind.' The Court reasoned that asthma, being a respiratory disease, is fundamentally different from the physical mutilations or disfigurements contemplated by Section 18. Therefore, the Referee's original 48% Non-Scheduled Disability rating had no legal basis. However, because the illness was work-aggravated, the Court found the petitioner entitled to medical reimbursement and services under Section 13, which does not require a loss of earning capacity for eligibility.
Main Doctrine
While an illness may be aggravated by employment conditions, disability compensation under the Workmen's Compensation Act is predicated on the loss or diminution of earning capacity, not merely on medical disability or pain and suffering. Furthermore, asthma is not a disease subject to percentage rating for non-scheduled disability under Section 18 of the Act.