Villavieja v. Marinduque Mining and Industrial Corporation
REITERATIONFacts
The Antecedents: Petitioner Remus Villavieja was employed as a helper by respondent Marinduque Mining and Industrial Corporation, tasked with operating and maintaining a trip conveyor machine. His work involved exposure to fumes, heat, physical strain, and other hardships. In May 1973, while employed, he underwent surgery for kidney trouble and resumed work in September 1973, continuing until his dismissal on January 23, 1975. Procedural History: On February 5, 1975, petitioner filed claims for injury/sickness benefits and reimbursement of medical expenses. The claim was uncontroverted, and the Chief of the Workmen's Compensation Unit awarded the claims. Respondent corporation filed a petition for review, alleging lack of due process and that the illness was not work-connected. The Workmen's Compensation Commission en banc reversed the award, stating that the grant of 50% Non-Scheduled Disability (NSD) was without basis as there was no NSD for the illness under the New Schedule of Compensation. The Petition: Petitioner seeks review of the Commission's decision, arguing that it committed grave abuse of discretion in reversing the award and dismissing the case, including reimbursement for medical expenses, and in holding the kidney stone illness as non-compensable.
Issue(s)
Whether the respondent Commission committed grave abuse of discretion in reversing the award of the Chief, Workmen's Compensation Unit, and dismissing the case. Whether the illness due to stones of the kidney is compensable as a Non-Scheduled Disability (NSD). Whether petitioner is entitled to reimbursement for medical expenses.
Ruling
The petition is GRANTED. The decision of the respondent Workmen's Compensation Commission is REVERSED and SET ASIDE. The decision of the Chief, Workmen's Compensation Unit, Felicito D. Ciocon, dated November 12, 1975, is REINSTATED. Respondent Marinduque Mining and Industrial Corporation is ordered to pay petitioner-claimant disability compensation benefits, reimburse medical and hospital expenses, pay attorney's fees, and pay administrative expenses.
Ratio Decidendi
On the grave abuse of discretion and dismissal of the case: The Court reiterated the well-settled principle that an employee's illness supervening during employment is presumed to have arisen out of or at least been aggravated by the employment, shifting the burden of proof to the employer. This presumption is mandated by Section 44 of the Workmen's Compensation Act. The records showed that the petitioner's right to compensation was not controverted by the respondent employer before the Chief of the Workmen's Compensation Unit. Failure to controvert constitutes a renunciation of the employer's right to challenge the claim and a waiver of all non-jurisdictional defenses, including the defense that the illness is not compensable. This failure to controvert is equivalent to a waiver of the right to due process, allowing an award to be issued without a formal hearing, as held in numerous cases. The employer may no longer be heard to complain after failing to avail of its rights under the law, especially in the absence of any petition for reinstatement of the right to controvert or claim of fraud. On the compensability of kidney stone illness as Non-Scheduled Disability (NSD): The Court noted that the respondent Commission's assertion that there was no NSD for kidney stones under the New Schedule of Compensation was flawed. While the specific illness might not be listed, the Schedule of Compensation, as a supplement to Article 18, paragraph 5 of the Workmen's Compensation Act, is not exhaustive. The Court pointed to a provision under "XX. THE ABDOMEN" concerning "Chronic diseases of any kind of the abdominal organs arising from industrial injury and resulting in permanent derangement of their functions, or impairment of nutrition." This provision, particularly the sub-category for "Severe" cases producing "marked impairment of nutrition or such symptoms as totally incapacitate the laborer from securing or retaining employment," could encompass the petitioner's condition. Furthermore, the Court found the evaluation of the Compensation Medical Rating Officer, who physically examined the petitioner, more reliable than the Associate Commissioner's conclusion based on general observation. On reimbursement for medical expenses: The Court found merit in the petitioner's challenge to the dismissal of his claim for reimbursement of medical expenses. Section 13 of the Workmen's Compensation Act mandates that the employer or insurance carrier shall provide necessary services, appliances, and supplies for the employee's recovery and restoration to maximum physical capacity. The law only allows denial of such reimbursement if the employee voluntarily refused or obstructed the provision of these services without justifiable cause, which was not shown in this case. Since the illness was deemed compensable and there was no relinquishment of rights by the petitioner, reimbursement for incurred medical expenses was deemed proper.
Main Doctrine
The failure of an employer to controvert a claim for compensation benefits under the Workmen's Compensation Act constitutes a renunciation of its right to challenge the claim and a waiver of all non-jurisdictional defenses, including the defense that the illness is not work-connected. Consequently, an award can be issued without a formal hearing.