Guevarra v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Fidel Guevarra was employed by the City of Manila as a garbage collector from 1949 until his retirement on January 31, 1972, at the age of 47, due to physical disability from pulmonary tuberculosis (PTB). His duties involved loading and unloading garbage, exposing him to heat, dust, and bad weather. PTB was discovered in 1969, and he received treatment from Dr. Tomas Josef from 1969 to January 1975, and from Dr. Romeo P. Pira from July 1969 to February 1972. Both physicians opined that his illness arose out of and was aggravated by his employment. An X-ray on January 29, 1975, showed PTB minimal, attributed to continuous medication. His service record did not indicate he stopped working due to disability. Procedural History: Petitioner filed a claim for disability compensation benefits on March 31, 1975. The respondent City of Manila received a copy of the claim on June 16, 1975, and filed its notice of controversion for lack of work connection on July 3, 1975, which was beyond the prescribed period. The claim was dismissed by the WCC Regional Office No. 4 on September 30, 1975, for the claimant's failure to appear and for discrepancies in the X-ray report dates. The Workmen's Compensation Commission affirmed the dismissal on February 18, 1976. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, seeking to set aside the decision of the Workmen's Compensation Commission.
Issue(s)
Whether the petitioner's illness of pulmonary tuberculosis arose out of or was aggravated by the nature of his employment. Whether the respondent City of Manila waived its right to controvert the claim by failing to file the notice within the prescribed period. Whether the petitioner is entitled to disability compensation benefits despite his service record not indicating he stopped working due to disability.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the City of Manila to pay petitioner disability compensation benefits, medical expenses, and attorney's fees.
Ratio Decidendi
On the issue of whether the petitioner's illness arose out of or was aggravated by his employment: The Court found it evident that petitioner was in good health when employed in 1949 and contracted PTB in 1969. His duties as a garbage collector exposed him to conditions conducive to contracting respiratory diseases. Both Dr. Josef and Dr. Pira certified that the illness arose out of and was aggravated by his employment, with Dr. Josef treating him from 1969 to 1975 and Dr. Pira from 1969 to 1972. The Court noted that tuberculosis is not an instantaneous disease and its incipient stage may not be readily discovered, making the X-ray finding in 1975 not necessarily contradictory to earlier diagnoses. The Court reiterated that under the Workmen's Compensation Act, an illness supervening during employment is deemed to have arisen out of or been aggravated by it. On the issue of whether the respondent City of Manila waived its right to controvert the claim: The Court held that the respondent employer failed to controvert the claim within the statutory period of 14 days from the date of disability or 10 days after knowledge thereof. The petitioner filed his claim on March 31, 1975, the respondent received a copy on June 16, 1975, and filed its controversion on July 3, 1975, which was 17 days after receiving the claim, thus exceeding the prescribed period. The Court emphasized that failure to controvert within the prescribed period amounts to a waiver of the right to controvert and a renunciation of all defenses, including the defense that the claim is not compensable, citing numerous precedents. On the issue of entitlement to disability benefits despite service record: The Court ruled that the respondent City of Manila knew of the petitioner's pulmonary tuberculosis as early as his retirement on January 31, 1972, yet failed to controvert the claim. Therefore, it could not question the compensability. The Court further stated that the approval of petitioner's optional retirement under R.A. 1616 at age 47 implied his physical incapacity to render efficient service, as per Memorandum Circular No. 133. This fact foreclosed the question of his disability, entitling him to disability benefits. The presumption of compensability, which arises when an illness supervenes during employment, becomes conclusive upon the failure of the employer to destroy it with substantial evidence, which the respondent failed to do.
Main Doctrine
The failure of an employer to controvert a claim for compensation within the prescribed period constitutes a waiver of the right to controvert and a renunciation of all defenses, including the defense that the claim is not compensable. Furthermore, an illness that supervenes during the course of employment is presumed to have arisen out of or been aggravated by the employment, and this presumption becomes conclusive if not rebutted by substantial evidence.