Batangas Laguna Tayabas Bus Company v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Leonardo Kalaw was employed as a conductor by Batangas Laguna Tayabas Bus Company (BLTB Company) from October 31, 1963, to August 25, 1967. During his employment, he experienced skin ailments, initially diagnosed as generalized dermatitis and later as allergy. On August 25, 1967, he stopped working due to his illness. On October 3, 1967, he consulted a specialist who diagnosed his condition as Hansen's disease (leprosy). Procedural History: On March 17, 1969, Leonardo Kalaw filed a claim for compensation. The Acting Chief of the Workmen's Compensation Unit ordered BLTB Company to pay compensation benefits. BLTB Company appealed to the Workmen's Compensation Commission (WCC), which affirmed the decision but increased the disability compensation benefits to P6,000.00, attorney's fees to P600.00, and administrative costs to P66.00. The Petition: BLTB Company filed a petition for certiorari, contending that Hansen's disease is not an occupational ailment and that the WCC erred in awarding benefits beyond the claimant's retirement date and even after alleged recovery.
Issue(s)
Whether Hansen's disease (leprosy) is a compensable illness under the Workmen's Compensation Act when aggravated by or resulting from the nature of employment. Whether the Workmen's Compensation Commission erred in awarding disability benefits beyond the claimant's actual retirement and after alleged full recovery.
Ruling
The petition is dismissed, and the decision of the Workmen's Compensation Commission is affirmed.
Ratio Decidendi
On the compensability of Hansen's disease: The Court held that the contention that Hansen's disease is not compensable is without merit. Evidence showed that the claimant's illness was traceable to his employment. A specialist testified that leprosy is a systemic disease that can be acquired through body contact and that factors like sudden changes in environment and temperature, and lessened body resistance, can contribute to its development or aggravation. As a conductor, Kalaw was inevitably exposed to different passengers and environmental changes, which could have strained his body resistance and contributed to his affliction or its aggravation. The Court reiterated the presumption under Section 44 of the Workmen's Compensation Act that a claim comes within its provisions in the absence of substantial evidence to the contrary, freeing the employee from the burden of proving the direct cause of the illness. The Court noted that the claimant had been suffering from skin diseases as early as 1966, indicating a gradual development of his illness up to his cessation of work in 1967, and that he was still positive for the disease as of July 1971, with no showing of cure or arrest by the time the WCC decided the case. Therefore, the award of maximum compensation was justified. On the award of benefits beyond retirement and alleged recovery: The Court found no error in awarding benefits beyond the claimant's retirement date, as the claim was filed on March 17, 1969, approximately one year and seven months after he stopped working. The Court cited Cañonero vs. Workmen's Compensation Commission et al., holding that failure to file within the period specified in Section 24 of the Act does not affect the Commission's jurisdiction, and that compensation claims under the Act prescribe in ten years pursuant to Article 1144(2) of the Civil Code. The WCC's award of P6,000.00 was based on a computation of 413 weeks of disability from August 25, 1967, up to July 24, 1975, reduced to the maximum allowed by law, reflecting the impairment of his earning capacity and the absence of proof of cure or arrest of his illness.
Main Doctrine
Hansen's disease (leprosy) is compensable under the Workmen's Compensation Act if it is proven to have been contracted or aggravated in the course of employment, and the presumption of compensability under Section 44 of the Act applies in the absence of substantial evidence to the contrary. Claims filed within ten years from the accrual of the cause of action are not barred by prescription.