Orellana v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Macaria Orellana commenced employment with respondent La Suerte Cigar & Cigarette Factory Inc. in 1957. Initially assigned as a packet maker and later as a cellophaner, her duties involved sitting before an electrically heated iron block. In 1964, she suffered an epileptic attack and was taken to the factory clinic. Subsequently, she was transferred to a "reject section" or "safer assignment." Due to the worsening of her condition, the factory physician, Dr. Balbino Dy, advised her to rest. Petitioner stopped working on October 5, 1968, due to her illness, diagnosed as epilepsy. Procedural History: On March 31, 1975, petitioner filed a compensation claim. The Hearing Officer of Regional Office No. 4 awarded disability benefits, attorney's fees, and administrative fees. Respondent La Suerte Cigar & Cigarette Factory Inc. received the decision on October 22, 1975. Its motion for reconsideration, filed on November 21, 1975 (30 days later), was denied for being filed out of time, and the respondent was directed to remit the awarded amounts. Respondent appealed to the Workmen's Compensation Commission (WCC), which reversed the Hearing Officer's decision, finding the illness not compensable. The Petition: Petitioner sought review of the WCC decision, arguing that her illness was compensable and that the Hearing Officer's decision had become final due to the respondent's late filing of its motion for reconsideration.
Issue(s)
Whether the motion for reconsideration filed by respondent La Suerte Cigar & Cigarette Factory Inc. was filed within the reglementary period. Whether the petitioner's illness, epilepsy, is compensable under the Workmen's Compensation Act. Whether the petitioner presented sufficient evidence to establish that her illness was caused by her employment.
Ruling
The Supreme Court reversed the decision of the Workmen's Compensation Commission. Respondent La Suerte Cigar & Cigarette Factory Inc. was ordered to pay petitioner P6,000.00 as disability compensation, P600.00 as attorney's fees, and P61.00 as administrative fee.
Ratio Decidendi
On the timeliness of the motion for reconsideration: The Court noted that the respondent's motion for reconsideration was filed thirty (30) days after receipt of the Hearing Officer's decision, which is beyond the reglementary period. However, the Court proceeded to resolve the petition on the merits. On the compensability of the illness: The Court held that the petitioner presented sufficient evidence to establish that she contracted epilepsy during her employment with La Suerte Cigar & Cigarette Factory Inc. and that the illness was caused by her employment as a cellophaner. The Court reiterated the principle under the Workmen's Compensation Act that an illness supervening during employment is presumed to be compensable. The petitioner did not solely rely on this presumption but provided adequate evidence to link her epilepsy to her work. The fact that she had to stop working due to the worsening condition of her illness further supported its connection to her employment. On the sufficiency of evidence: The Court found that the evidence presented by the petitioner was sufficient to prove that her illness of epilepsy was caused by her employment. This included testimony and the circumstances surrounding the onset and progression of her illness, which occurred during her tenure with the respondent company. The Court emphasized that the petitioner's illness was diagnosed as epilepsy and that she had to cease working because of its worsening condition, directly attributable to her employment conditions.
Main Doctrine
Under the Workmen's Compensation Act, an illness that supervened during employment is presumed to be compensable, and the claimant need not rely solely on this presumption if sufficient evidence is presented to establish that the illness was caused by employment.