Rombaoa v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Fausto Rombaoa, a seasonal laborer employed by Paniqui Sugar Mills, Inc. as a Boiling House Sampler, was found to be suffering from PTB minimal in September 1973. Due to this diagnosis, he was not re-employed for the subsequent milling crop year 1973-1974. The employer, Paniqui Sugar Mills, Inc., covered the claimant's medical expenses, including anti-TB treatment and chest examinations, from August 1973 until July 19, 1975. Procedural History: Rombaoa filed a claim for disability compensation with Regional Office No. III of the Department of Labor. This claim, along with twenty-three other similar cases, was dismissed by the Regional Office for lack of merit. The claimant then appealed to the Workmen's Compensation Commission. The Commission affirmed the dismissal, ruling that the claimant's illness could not be attributed to the nature of his work. The Petition: This case comes before the Supreme Court on a petition for review of the Workmen's Compensation Commission's decision. The petitioner argues that, similar to a companion case involving Florentino Hilario, his PTB minimal illness should be presumed to have arisen out of or been aggravated by his employment, especially given the employer's provision of medical care and the principle of resolving doubts in favor of labor. The petitioner seeks the same benefits awarded in the Hilario case, including disability compensation and attorney's fees.
Issue(s)
Whether the illness of the petitioner, PTB minimal, is compensable under the Workmen's Compensation Act. Whether the doubt in the implementation and interpretation of the Workmen's Compensation Act should be resolved in favor of labor.
Ruling
The decision of the Workmen's Compensation Commission is set aside. Paniqui Sugar Mills, Inc. is ordered to pay petitioner Fausto Rombaoa disability compensation benefits, attorney's fees, and administrative fees.
Ratio Decidendi
On the compensability of the illness: The Court reiterated the principle that if an employee contracts an illness during his employment, and in the absence of other circumstances, it is presumed that the nature and conditions of his employment contributed to the illness. The fact that the petitioner was found fit for work in a prior season does not preclude the possibility that the disease supervened during his employment. The Court emphasized that employers are not legally allowed to dismiss sick or disabled workers without providing the proper compensation as mandated by the Workmen's Compensation Act. The Court also invoked Article 4 of the Labor Code, which mandates that all doubts in the implementation and interpretation of labor laws shall be resolved in favor of labor. This principle was applied to the petitioner's case, similar to the case of Florentino Hilario, where the WCC granted compensation despite the employer's contention that the illness could have been contracted during the off-milling season. The Court found the employer's reasoning fallacious, as the disease could have certainly supervened during the period of employment. The Court further cited the ruling in Caltex (Philippines), Inc. vs. Derpo, et al., which affirmed that pre-employment examinations showing fitness for work, followed by the contraction of an illness like tuberculosis, indicate that the employment contributed to the illness. On resolving doubts in favor of labor: The Court explicitly stated that Article 4 of the amended Labor Code mandates that all doubts in the implementation and interpretation of the provisions of the Labor Code, including its implementing rules and regulations, shall be resolved in favor of labor. This principle is a cornerstone of labor law jurisprudence, ensuring that the protective mantle of the law is extended to workers. The Court applied this principle to the case at bar, noting that even if there was doubt on the exact date of the inception of the petitioner's disease, such doubt must be resolved in favor of the claimant. This aligns with the WCC's reasoning in the Hilario case, where it stated that the doubt should not be a drawback to compensability and should be resolved in favor of the claimant. The Court's decision underscores the legislative intent to provide a social security system for workers, protecting them from the hazards of their employment.
Main Doctrine
The presumption of compensability for illness under the Workmen's Compensation Act applies, and any doubt in the implementation and interpretation of the law shall be resolved in favor of labor. An employer is not permitted to dismiss sick or disabled workers without proper compensation.