Francisco v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Cayetano Francisco, employed as a ditchtender by the National Irrigation Administration (NIA) for 26 years, experienced frequent backaches, chest pains, and physical weakness. He was diagnosed with pulmonary tuberculosis. He gave oral notice of his sickness to the NIA and stopped working. Procedural History: Francisco filed a claim for compensation benefits. The hearing officer dismissed the claim, and a motion for reconsideration was also dismissed. The Workmen's Compensation Commission (WCC) reversed the dismissal and granted permanent partial disability benefits under Section 18 of the Workmen's Compensation Act. The Petition: Francisco appealed to the Supreme Court, praying for permanent total disability compensation under Section 15 of the Act, asserting that his sickness rendered him totally and permanently disabled for any other kind of work.
Issue(s)
Whether the petitioner is entitled to permanent total disability benefits under Section 15 of the Workmen's Compensation Act. Whether the respondent employer's failure to controvert the claim, despite notice, affects the jurisdiction of the Hearing Officer and the Commission over the Republic.
Ruling
The Supreme Court affirmed the decision of the respondent Commission declaring the petitioner's illness as compensable but modified the award of benefits to allow compensation under Section 15 of the Workmen's Compensation Act for permanent total disability. The respondent employer was ordered to pay the claimant P6,000.00 as compensation, reimburse medical expenses, pay attorney's fees, and pay administrative fees.
Ratio Decidendi
On the entitlement to permanent total disability benefits: The Court found the petition impressed with merit, citing the Physician's Report of Sickness which established not only the causal relation between the petitioner's work and his sickness but also that his disability is permanent and total. The report indicated that the illness could be traced to the nature of his employment (constant exposure to dust and overwork), that it caused total disability for labor for an indefinite period, that he cannot resume his former occupation, and that he cannot do any other kind of work, resulting in permanent total disability for labor. This finding was confirmed by an x-ray report showing PTB, Minimal Chronic, Right. The respondent employer submitted no evidence to controvert the claim. On the jurisdiction over the Republic: The Court rejected the contention of the Republic, through the Solicitor General, that it could not be made to answer for the disability claim due to lack of notice and representation. The Court cited Dinaro vs. WCC and Republic and Memorandum Circular No. 210 of the Office of the President, which state that the duty to file the notice of controversion of claims for government employees devolves upon the heads of the concerned departments, bureaus, or offices. The Court held that the provision for transmittal of claims against the government in GAO Circular No. 69 cannot be an instrument of injustice against the claimant-employee nor override the statutory sanction for non-controversion. Since the petitioner duly notified the National Irrigation Administration (NIA) of his claim, as contemplated under the revised procedure, the NIA's failure to notify the Solicitor General of its decision to controvert the claim could not be faulted against the petitioner. Therefore, the Court found that the petitioner had duly notified the Republic of his claim through the NIA, and the failure to controvert was the employer's responsibility, thus the Hearing Officer and the Commission acquired jurisdiction.
Main Doctrine
An employee suffering from permanent total disability due to an illness contracted in the course of employment is entitled to permanent total disability benefits under Section 15 of the Workmen's Compensation Act, and the employer's failure to controvert the claim, despite proper notice, precludes them from questioning jurisdiction over the claim.