Central Azucarera Don Pedro v. Workmens Compensation Commission
REITERATIONFacts
The Antecedents: Nemesio Tanio, employed by Central Azucarera Don Pedro (CENTRAL) as a laborer and later as an operator of a cane-unloading machine, stopped working on February 9, 1960, due to spitting blood. An x-ray revealed minimal pulmonary tuberculosis (PTB) in his right lung. He was confined in the CENTRAL's hospital but refused further treatment after three days and was discharged at his request, later affirming this in an affidavit. He retired and received P400.00 as gratuity. Procedural History: Three years later, on October 8, 1963, Tanio filed a complaint for disability compensation and medical expenses. The Hearing Officer dismissed the case for lack of merit, finding no corroboration for his symptoms, no resulting disability, and that mere proof of illness does not entitle an employee to compensation. The Workmen's Compensation Commission (WCC) reversed this, presuming the PTB was caused or aggravated by employment, as Tanio was healthy upon hiring. The WCC ordered the CENTRAL to pay disability compensation, medical expenses, attorney's fees, costs, and to provide further medical services. The CENTRAL's motion for reconsideration was denied, though a Medical Member dissented, stating the PTB was minimal and not aggravated. The Petition: The CENTRAL filed a petition for review, raising issues of jurisdiction, interpretation of Sections 24 and 45 of the Workmen's Compensation Act, entitlement to medical expenses despite waiver, and the award of attorney's fees.
Issue(s)
Whether Regional Office No. 4 had jurisdiction over Tanio's claim. The proper interpretation of Sections 24 and 45 (paragraph 2) of Act 3428 (Workmen's Compensation Act). Whether Tanio was entitled to reimbursement of medical expenses despite his voluntary waiver of proffered medical treatment. Whether attorney's fees were correctly awarded despite the absence of any prayer therefor in Tanio's complaint.
Ruling
The Supreme Court modified the decision of the Workmen's Compensation Commission by striking therefrom the award of P1,300.00 for medical expenses and the order for continued medical services. In all other respects, the decision was affirmed, with costs against Central Azucarera Don Pedro.
Ratio Decidendi
On the jurisdiction of Regional Office No. 4: The Court affirmed that Regional Office No. 4 validly assumed jurisdiction over the claim. Under Section 1, Rule 16 of the WCC Rules, a claim can be filed in the regional office where the accident occurred, where the claimant resides, or where the respondent resides, at the claimant's option. Tanio opted to file in Manila, and it was established he resided in Sta. Cruz, Manila, at the time of filing, thus satisfying the rule for the claimant's convenience. On the interpretation of Sections 24 and 45 of the Workmen's Compensation Act: The Court found the CENTRAL's contention that Tanio's claim was prescribed due to lack of notice to be without merit. The employer's act of confining and treating Tanio at its expense for three days upon discovery of his illness sufficed and obviated the necessity of formal notice as required by Section 24. The Court reiterated that delay or failure to give notice does not bar a claim if the employer had actual knowledge or suffered no damage from the delay, citing Balanga vs. Workmen's Compensation Commission, et al.. Furthermore, the CENTRAL's failure to controvert Tanio's claim within the periods prescribed by Section 45 of the Act meant it waived its right to controvert on non-jurisdictional grounds, as per Capinpin v. WCC and Vda. de Eustaquio v. WCC. On entitlement to reimbursement of medical expenses despite waiver: The Court ruled that Tanio was not entitled to reimbursement for medical expenses nor to further medical services. The right to medical attendance under Section 13 of the Act can be abated if the employee unreasonably refuses or voluntarily impedes the medical services proffered by the employer. Tanio's refusal of further treatment after three days and his subsequent discharge at his request, confirmed by affidavit, constituted such an impediment, citing Lerma v. WCC. On the award of attorney's fees: The Court found the CENTRAL's allegation regarding the award of attorney's fees without a prayer to be devoid of merit. The insertion of the phrase "which shall be chargeable against the employer" in Section 31 of the Workmen's Compensation Law by Rep. Act 4119 indicated the legislative intent to make attorney's fees an integral part of the benefits. As Section 31 fixes the amount, a specific prayer and proof are no longer necessary, citing Manila Electric Company v. WCC.
Main Doctrine
An employer's act of providing and paying for medical assistance to an employee exhibiting symptoms of illness obviates the necessity of formal notice of illness required by the Workmen's Compensation Act. Furthermore, failure to controvert a claim within the statutory period results in a waiver of the right to controvert on non-jurisdictional grounds. Attorney's fees are awardable under Section 31 of the Act, as amended by Rep. Act 4119, without need for a specific prayer or proof.