Matta v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Florentino R. Matta was employed by the Development Bank of the Philippines (DBP) from January 1, 1947, to October 31, 1972, in various capacities. While serving as chief guard, he met an accident on January 18, 1960, when fire broke out at the DBP building. During the attempt to extinguish the fire, his eyes were sprayed with poisonous caustic soda from a fire extinguisher, causing him to be hospitalized and subsequently experience blurring of vision. He was later operated on for "cataract-bilateral" and was diagnosed with diabetes mellitus and heart ailment, all of which he claimed were contracted during his employment. Procedural History: Petitioner filed a Notice of Injury or Sickness and Claim for Compensation on March 30, 1975, alleging disability due to illness contracted while in service. The DBP controverted the claim, stating the illness was not compensable and not caused or aggravated by his work. The Acting Referee denied the claim, finding no relation between his work as assistant purchasing officer and his illness. The Workmen's Compensation Commission affirmed the denial, ruling that "cataract-bilateral" is not compensable as it is a result of aging and that there was no evidence to support the claim. The Petition: Petitioner seeks reversal of the Commission's decision, arguing that his ailments are work-connected and that the presumption of compensability under the Workmen's Compensation Act should favor him.
Issue(s)
Whether the petitioner's illness, "cataract-bilateral" coupled with diabetes mellitus and heart ailment, is compensable under the Workmen's Compensation Act. Whether the respondent employer failed to controvert the claim within the period prescribed by law.
Ruling
The Supreme Court reversed the decision of the respondent Workmen's Compensation Commission. The Development Bank of the Philippines was ordered to pay petitioner disability compensation benefits, reimburse medical and hospital expenses, and pay attorney's fees.
Ratio Decidendi
On the compensability of the illness: The Court reiterated the presumption of compensability under Section 44 of the Workmen's Compensation Act, stating that once an illness supervenes during employment, it is presumed to have arisen out of or been aggravated by the employment, unless the employer presents substantial evidence to the contrary. The Court noted that the petitioner was found physically fit upon employment and that the accident involving caustic soda directly affected his eyes, leading to his subsequent ailments. The physician's report indicated that the injury or illness was caused by and/or aggravated by the employment. The Court emphasized that strict rules of evidence are not applicable in compensation cases, and a reasonable work-connection or an increased risk of contracting the disease due to working conditions is sufficient. The contention that the illness was due to aging was deemed a conjecture, as the law applies to both young and old, and employment-related exertions can be contributing or aggravating factors. The Court further stated that even if other factors like advancing age contributed, the employment's contribution, even if small, makes the ailment compensable. On the failure to controvert the claim: The Court found that the respondent's controversion was filed on October 2, 1975, which was beyond the period allowed by law. According to Section 45 of the Workmen's Compensation Act, the employer should have filed its notice to controvert within fourteen days of disability or within ten days of knowledge of the illness. The respondent's failure to file a timely and reasonable controversion constituted a renunciation of its right to controvert the claim, making its compensability beyond challenge. The Court concluded that in labor laws, doubts should always be resolved in favor of the workers.
Main Doctrine
The presumption of compensability under the Workmen's Compensation Act is rebuttable only by substantial evidence. Failure of the employer to controvert the claim within the statutory period constitutes a renunciation of its right to controvert, making the claim's compensability beyond challenge.