Bello v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Mauricio Bello was an employee of respondent Hector Lagman, a jeepney operator. Petitioner was diagnosed with "pulmonary tuberculosis, chronic, moderately advanced predominantly fibrotics," which his attending physician declared was aggravated by his employment. He was confined at Quezon Institute from May 27, 1971, to June 20, 1971, after which he resumed working. He was later diagnosed with bacterial conjunctivitis from September 20, 1974, to October 16, 1976. Procedural History: Petitioner filed a claim for disability compensation. An initial award was made by the Acting Chief of the Workmen's Compensation Section, Region 4, Manila. Respondent Lagman moved to set aside the award, which was granted. The case was treated as a controverted claim, and the Hearing Officer dismissed petitioner's claim for lack of merit. On appeal, the Workmen's Compensation Commission (WCC) applied the legal presumption under Section 44 of the WCC Act, sustained the compensability of the claim, absolved Benedicto Dinglasan and Sons, Inc., and held respondent Lagman liable. The WCC granted temporary total disability for the periods of confinement only, amounting to P178.28. The Petition: Petitioner sought a review of the WCC decision, arguing that the lump sum awarded was insufficient and did not reflect the full compensation benefits due to him.
Issue(s)
Whether petitioner is entitled to full compensation benefits for his illness. Whether the award of P178.28 by the Workmen's Compensation Commission is sufficient and proper.
Ruling
The decision of the respondent Workmen's Compensation Commission dated February 23, 1976, is SET ASIDE. Respondent Hector Lagman is ordered to pay petitioner the sum of SIX THOUSAND PESOS (P6,000.00) as disability compensation and to pay Counsel of petitioner attorney's fees equivalent to 10% of the recoverable amount, with costs against respondent Lagman.
Ratio Decidendi
On whether petitioner is entitled to full compensation benefits for his illness: The Court found the petition meritorious and held that full compensation benefits are in order. It was undisputed that petitioner was afflicted with pulmonary tuberculosis during the course of his employment. The Court emphasized that a doctor's certification as to the nature of a claimant's disability may be given credence, and laboratory reports, such as chest x-ray reports, are not indispensable prerequisites to the compensability of a claim. The absence of an x-ray report cannot prejudice such a claim. The Court reiterated that it is enough that the hypothesis on which the workmen's claim is based is probable, and medical opinion to the contrary can be disregarded. The niceties and refinements of technical rules on procedure must give way to effect substantial justice to the claimant. The Court also noted that the disease occurred not only on May 27, 1971, but recurred on various dates in 1974 and 1975, and that Section 2 of the Workmen's Compensation Act provides compensation for illness directly caused by, aggravated by, or the result of the nature of employment. Numerous cases involving substantially similar conditions have ruled that tuberculosis is an occupational disease, hence, compensable. Petitioner has been rendered incapable of further pursuing his usual work because of his weakened bodily condition due to illness contracted in the course of employment. On whether the award of P178.28 by the Workmen's Compensation Commission is sufficient and proper: The Court found the award of P178.28 to be unsubstantial and unrealistic considering present-day economic standards and financial realities. To sustain such a meager award would render meaningless the purpose of the law and the social justice precept it guarantees. The WCC's decision to grant benefits solely for the period of confinement was deemed erroneous, especially considering the recurrence of the illness and the provisions of the Workmen's Compensation Act. The Court concluded that the petitioner is entitled to full compensation, which was fixed at P6,000.00, the maximum allowable under the law, to reflect the substantial and realistic economic needs of the claimant.
Main Doctrine
Tuberculosis contracted during the course of employment is an occupational disease and is compensable. The employee is entitled to full compensation benefits if rendered incapable of pursuing usual work due to illness aggravated by employment, and the award should not be limited to confinement periods but should reflect substantial and realistic economic standards.