De Los Santos v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Juan de los Santos, a classroom teacher, joined the government in June 1930. In May 1947, he was diagnosed with pulmonary tuberculosis (PTB), minimal, and returned to work after treatment. In February 1971, he again suffered from PTB, forcing him to go on leave. A check-up in June 1971 confirmed PTB, moderately advanced, leading him to stop working on July 4, 1971, and apply for retirement, which was approved on July 4, 1973. Procedural History: The Acting Referee awarded compensation benefits, finding that petitioner had 41 years of service and that his illness was contracted or aggravated by his employment. The Workmen's Compensation Commission reversed this, stating the illnesses were not disabling and questioning why petitioner continued working if they were disabling since 1965. The Petition: Petitioner seeks to set aside the decision of the Workmen's Compensation Commission and reinstate the award of compensation benefits.
Issue(s)
Whether the Workmen's Compensation Commission erred in reversing the Acting Referee's award of compensation benefits. Whether the petitioner's illnesses were disabling and contracted or aggravated by his employment.
Ruling
The decision of the respondent Workmen's Compensation Commission dated January 30, 1976, is SET ASIDE, and the judgment of Acting Referee Tomas G. Montisenes is REINSTATED and AFFIRMED.
Ratio Decidendi
On the issue of whether the Workmen's Compensation Commission erred in reversing the Acting Referee's award of compensation benefits: The Supreme Court found merit in the petition, reversing the Commission's decision. The Court noted that the petitioner was diagnosed with pulmonary tuberculosis as early as 1947 and again in 1971, with the latter diagnosis indicating a moderately advanced stage. The Court emphasized that the Workmen's Compensation Law should be construed liberally in favor of employees, and any doubts regarding the right to compensation should be resolved in their favor. This principle of social justice mandates protection for the laborer against the employer's superior resources. The Court found that the petitioner's illnesses, including chronic nephritis, rheumatoid arthritis, and chronic bronchial asthma, in addition to PTB, were certified by a physician as having been caused or aggravated by the nature of his employment as a public school teacher and property custodian. The Court cited Madrigal Shipping Co. vs. Melad to support the liberal interpretation of the law for the benefit of employees. On the issue of whether the petitioner's illnesses were disabling and contracted or aggravated by his employment: The Court affirmed the Acting Referee's finding that the petitioner's illness was contracted during his employment or at least aggravated by its nature. The medical report from Dr. Salvador Arevalo explicitly stated that the petitioner's various ailments, including PTB moderately advanced, could have been caused and/or aggravated by his employment. The recurrence of PTB in 1971, forcing him to stop working, further supported the claim of disability. The Court distinguished this from the Commission's view that the illnesses were not disabling, highlighting that the petitioner's continued work until retirement did not negate the disabling nature of the illness, especially given its recurrence and progression. The Court also referenced Victorias Milling vs. Workmen's Compensation Commission to underscore the principle of social justice in protecting laborers.
Main Doctrine
The Workmen's Compensation Law should be construed liberally in favor of employees, and doubts as to the right of compensation should be resolved in their favor, especially when the illness is aggravated by the nature of employment.