Aguirre v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Honorata M. Aguirre, a permanent elementary grade school teacher, filed a claim for compensation on March 5, 1975, alleging that on December 13, 1974, she was forced to stop teaching due to an illness diagnosed as "meningoencephalitis, aseptic, acute and anemia moderate." She was confined from December 25, 1974, to January 13, 1975, and took extended leaves of absence. Procedural History: A notice of the claim was sent to the Office of the Solicitor General in March 1975, but a controversion was filed only on May 16, 1975. The claim was heard, and on October 30, 1975, the Hearing Officer issued an award granting compensation benefits, including compensation, reimbursement of medical expenses, and attorney's fees. The Petition: The claimant, Honorata M. Aguirre, filed a petition for review, finding the decision of the Workmen's Compensation Commission, which stated she did not suffer any disability for labor, to be incomprehensible given the evidence presented.
Issue(s)
Whether the claimant suffered a disability for labor compensable under the Workmen's Compensation Act. Whether the claim for compensation is governed by the Workmen's Compensation Act or the New Labor Code. Whether the employer timely controverted the claim.
Ruling
The Supreme Court set aside the decision of the respondent Commission and modified the referee's award. The employer was directed to pay Honorata M. Aguirre P6,000.00 as disability compensation, P3,512.90 as reimbursement of medical expenses, P600.00 as attorney's fees, and P61.00 to the Workmen's Compensation Fund as an administrative fee.
Ratio Decidendi
On the issue of disability for labor: The Court found it incomprehensible that the Commission stated the claimant did not suffer any disability when the evidence clearly showed she stopped teaching due to her ailment, requiring hospitalization and extended leaves of absence. Disability, as defined in Bello v. Workmen's Compensation Commission, occurs when an employee is unable to perform work in the usual and customary way due to physical inability, resulting in a loss or diminution of earning power. The claimant's ailment, meningoencephalitis, characterized by inflammation of the brain and meninges, can cause physical and mental incapacitation, making it understandable why she could not pursue her teaching work, especially with the mental strain involved in handling young children. The Court reiterated that it is not necessary to inquire into the exact cause of the sickness, as long as it occurred or was aggravated in the course of employment, applying the legal presumption of compensability. On the governing law (Workmen's Compensation Act vs. New Labor Code): The Court rejected the argument that the claim should be governed by the New Labor Code because the disability occurred after January 1, 1975. The Court cited De Castro Jr. v. Workmen's Compensation Commission, where it held that the fact of death occurring during the effectivity of the New Labor Code did not divest the Workmen's Compensation Commission of jurisdiction if the illness supervened when the Workmen's Compensation Act was in full force and effect. In this case, the claimant's ailment and disability commenced on December 13, 1974, when the Workmen's Compensation Act was in effect, thus making it the applicable law. On the timely controversion of the claim: The Court noted that the employer failed to controvert the claim on time. The notice of claim was sent in March 1975, and the controversion was filed on May 16, 1975, which was beyond the ten-day period required by Section 45 of the Workmen's Compensation Act after notice. By failing to file the controversion on time, the employer is deemed to have renounced all non-jurisdictional defenses and admitted the compensability of the claim, citing Pros v. WCC and other cases.
Main Doctrine
A claim for compensation is presumed compensable under Section 44 of the Workmen's Compensation Act, and this presumption is not overcome by the employer's failure to present evidence to overthrow it or to controvert the claim on time. The law in force at the time the ailment and disability commenced governs the claim.