Villareal v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Paterno Villareal, a laborer for the City of Caloocan (Health Department), filed a claim for compensation due to pulmonary tuberculosis, an illness he alleged supervened during his employment. He retired from service on July 5, 1970, due to illness. The claim was based on the assertion that his pulmonary tuberculosis was a work-connected disease that incapacitated him for labor. Procedural History: Villareal filed his Notice of Injury or Sickness and Claim for Compensation on August 2, 1971. The Acting Referee of the Workmen's Compensation Unit, Regional Office No. 4, Manila, initially dismissed the claim for insufficiency of evidence. A motion for reconsideration was denied, and the case was elevated to the Workmen's Compensation Commission. The Commission affirmed the Acting Referee's decision, absolving the City of Caloocan (Health Department) from liability. The Petition: This case comes before the Supreme Court as a petition for review of the Workmen's Compensation Commission's decision. The petitioner argues that his illness of pulmonary tuberculosis is compensable and that the claim was not filed out of time. The petition contends that the City of Caloocan waived its defenses by failing to controvert the claim and that there is a disputable presumption that the illness arose out of employment, shifting the burden of proof to the employer. The petitioner also asserts that the ten-year prescriptive period for compensation claims commences from the date of disability, not the onset of illness.
Issue(s)
Whether the illness of Paterno Villareal of pulmonary tuberculosis is compensable. Whether the claim for compensation was filed out of time.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The City of Caloocan (Health Department) is ordered to pay the heirs of Paterno Villareal P6,000.00 as disability benefit, P600.00 as attorney's fees, and P61.00 as administrative fee.
Ratio Decidendi
On the issue of whether the illness is compensable: The Court found that tuberculosis is an imperceptible disease, and exposure to dust and dirt, common in a laborer's work, is a predisposing cause. The causal connection between the claimant's ailment and the nature of his employment as a laborer was discernible, indicating that the illness supervened in the course of employment and was directly caused or aggravated by it. Furthermore, by failing to controvert the claim within the reglementary period, the respondent City of Caloocan (Health Department) waived all defenses except lack of jurisdiction. The pulmonary tuberculosis of Paterno Villareal having supervened during his employment, there is a disputable presumption that the claim is compensable, relieving the claimant of the duty to prove causation. On the issue of whether the claim was filed out of time: The Court ruled that the contention that the claim was filed out of time was without merit. Citing previous rulings, the Court reiterated that the defense of late filing is not jurisdictional and that the statutory right to compensation prescribes in ten (10) years. The ten-year prescriptive period commences from the time the employee is disabled to pursue his occupation by reason of illness. In this case, the illness allegedly supervened in 1969, and the claim was filed in 1971, well within the ten-year prescriptive period.
Main Doctrine
The ten-year prescriptive period for compensation cases commences from the time the employee is disabled to pursue his occupation by reason of illness. Failure to controvert a claim waives all defenses except lack of jurisdiction. Illness supervening during employment is disputably presumed to be compensable.