Roman Labenia v. Workmen's Compensation Commission and Philippine Iron Mines, Inc.
REITERATIONFacts
The Antecedents: Petitioner Roman Labenia was employed by respondent Philippine Iron Mines, Inc. as a truckman from 1943 until his retirement on November 30, 1973. He stopped working on June 18, 1973. On December 17, 1973, he consulted Dr. Avelino T. Marfori, who diagnosed him with "PLEURO DIAPHGRAGMATIC ADHESION RIGHT, POST INFECTION." The medical report indicated that the illness was caused by infection, was contracted directly by and in pursuance of his employment, and resulted in temporary total disability for labor for an indefinite period. The report also stated that prior to employment, the subject patient did not manifest the findings. Procedural History: On July 29, 1974, Labenia filed a claim for compensation. The Workmen's Compensation Section in Manila issued a decision in his favor on January 24, 1975, awarding benefits, citing the medical report and the respondent's failure to controvert the claim within the prescribed period. Respondent company filed a motion for reconsideration, arguing that it had filed its Employer's Report and Notice of Controversion with the Regional Office in Naga City, thus the award was contrary to law and due process. The motion was denied but treated as a petition for review. The Workmen's Compensation Commission reversed the decision, absolving the company, and ruled that the illness was acquired after retirement, finding no competent medical evidence to trace the illness to his employment. The Commission noted that treatment began on December 17, 1973, almost six months after he stopped working. The Petition: Petitioner seeks entitlement to disability benefits under the former Workmen's Compensation Act, questioning whether the medical report constitutes competent evidence that the claimant contracted the illness during his employment.
Issue(s)
Whether a medical report of sickness and accident is competent evidence to establish that the claimant contracted the illness during his employment under the former Workmen's Compensation Act. Whether the illness of pleuro-diaphragmatic adhesion, right, post infection, contracted by the petitioner, supervened during his employment.
Ruling
The petition is dismissed for lack of merit. The decision of the respondent Workmen's Compensation Commission is affirmed.
Ratio Decidendi
On the issue of whether a medical report is competent evidence that the illness supervened during employment: The Court held that while under the former Workmen's Compensation Act, there was a presumption of compensability and a liberal approach favoring the claimant where an illness supervened during employment, this presumption required that the illness must have indeed supervened during employment. Competent evidence must show when the illness was contracted. In this case, the medical report, while stating the illness was contracted during employment, was issued on December 17, 1973, almost six months after the petitioner stopped working on June 18, 1973. The Court distinguished this from prior cases where physician's reports were deemed sufficient because the claimant had been examined while employed or within a reasonable time thereafter. Here, there was no basis to conclude that the illness diagnosed on December 17, 1973, was already present when the claimant was still working. The terse diagnosis in a form, long after the petitioner stopped working, was insufficient. The Court found a want of competent medical evidence to establish that the illness supervened during employment, thus sustaining the Workmen's Compensation Commission's factual finding. On the issue of whether the illness supervened during employment: The Court affirmed the Commission's finding that the illness was acquired after retirement. The petitioner stopped working on June 18, 1973, and was considered retired on November 30, 1973. His consultation with Dr. Marfori was on December 17, 1973. The diagnosis of "pleuro-diaphragmatic adhesion right, post infection" made at this late stage, without any prior medical examination or treatment during his employment, did not provide competent evidence that the illness was contracted or aggravated during his service with the respondent company. The nature of the illness, described as an adhesion of the tissues of the lungs and diaphragm resulting from an infection, requires more than a post-employment diagnosis to establish its work-related origin or aggravation.
Main Doctrine
A medical report diagnosing an illness is competent evidence for disability benefits under the former Workmen's Compensation Act only if it establishes that the illness was contracted or supervened during the period of employment. A diagnosis made long after the cessation of employment, without proof of its prior existence, is insufficient to establish compensability.