Bambalan v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Bernardo Bambalan, an employee of Universal Textiles Mills, Inc., filed a claim for sickness benefits with the Workmen's Compensation Commission (WCC) for ailments of Pyelonephritis (kidney) acute and Bronchitis, acute, alleging these were suffered in the course of or aggravated by his employment as a machine operator. He had been employed since May 2, 1972, earning P11.80 daily. 2. Procedural History: The petitioner's claim, RO4-WC Case No. 7402, was initially dismissed by the WCC Unit Head for non-appearance. A motion for reconsideration was denied, but the case was forwarded to the WCC for review. The WCC affirmed the dismissal, finding no substantial evidence and no causal relation between the ailments and employment. A subsequent motion for reconsideration was also denied, leading to the current petition for review on certiorari. 3. The Petition: The petitioner seeks review of the WCC's decision, arguing that the WCC gravely erred in dismissing his claim despite ample submitted evidence and the respondent company's failure to controvert the claim. He contends that the strict rules of evidence should not apply in compensation cases and that his ailments were either caused by or aggravated by his employment conditions, including prolonged standing, stooping, night shifts, exposure to temperature variations, and cotton dust, which could lead to kidney inflammation and bronchitis. The petitioner also asserts that the employer's failure to controvert the claim within the prescribed period, as per Section 45 of the Workmen's Compensation Act, should render the claim compensable.
Issue(s)
Whether the WCC gravely erred in dismissing the petitioner's claim for compensation. Whether the documents submitted by the petitioner were sufficient to support his claim; and whether the strict rules of evidence are applicable in workmen's compensation cases. Whether the respondent company's failure to controvert the claim affects its compensability. Whether the petitioner's ailments arose out of or were aggravated by his employment. Whether the petitioner's computation of compensation is correct.
Ruling
The petition is granted. The judgment appealed from is reversed and set aside, ordering the respondent company to pay the petitioner P1,274.40 in compensation benefits, plus 10% attorney's fees.
Ratio Decidendi
On the dismissal of the claim: The Court found merit in the petition, holding that the documents submitted by the petitioner, including a Notice of Injury or Sickness and Claim for Compensation, Physician's Report, Claimant's Affidavit, medical certificates, and a co-worker's affidavit, were sufficient to support his claim. The rejection of these documents by the WCC on the ground that they lacked the necessary element for credence on their face value alone was unjustified. On the sufficiency of evidence and applicability of strict rules of evidence: The Court reiterated that the strict rules of evidence are not applicable in claims for compensation, as provided by Rule 10 of the Rules of the WCC, which mandates that proceedings be conducted without regard to technicalities, legal forms, and technical rules on evidence. The Court cited Batangas Trans Co. vs. Valenzuela and Dinaro vs. WCC to support the admissibility of medical certificates and the non-necessity of verification for documents to be considered substantial evidence. On the failure to controvert the claim: The Court emphasized that the respondent company had failed to controvert the petitioner's claim for compensation. The employer had been notified of the employee's ailment, and the employee had sought treatment in the company's medical clinic, with the company physician even recommending hospitalization. However, there was no evidence of controversion. The Court held that the failure to controvert the right of the claimant within the period prescribed in Section 45 of the Workmen's Compensation Act renders the claim compensable and its reasonableness and validity beyond challenge. The absence of controversion is fatal to any defense the employer could interpose, as established in La Mallorca vs. WCC. On the compensability of the ailments: The Court found that the petitioner's ailments, Pyelonephritis acute and Bronchitis acute, which supervened during his employment, either arose out of, or at least, were aggravated by his employment, thus making them compensable. The Court referenced its ruling in Ceniza vs. ECC which explained how Pyelonephritis could be caused by prolonged sitting and delayed urination, habits necessitated by a teacher's duties. Applying this reasoning to the petitioner, a machine operator whose work is hard, continuous, requires standing, stooping, and exposure to varying temperatures and cotton dust, it was not unlikely that he would postpone urination, leading to Pyelonephritis. His acute bronchitis was also deemed potentially caused by inhalation of cotton dust in his work area. On the computation of compensation: The petitioner computed his compensation for Temporary Total Disability based on 210 compensable days (30 compensable weeks), with a weekly compensation of P70.80 (P11.80 daily wage x 6 days), and a 60% rate, resulting in P42.48 per week. The total compensation claimed was P1,274.40 (P42.48 x 30 weeks). The Court found this computation to be correct and awarded the amount, plus attorney's fees.
Main Doctrine
The Workmen's Compensation Commission (WCC) committed grave error in dismissing the petitioner's claim for sickness benefits. The submitted documents were sufficient to support the claim, and the strict rules of evidence are not applicable in compensation cases. Furthermore, the employer's failure to controvert the claim rendered it compensable and beyond challenge. The petitioner's ailments, Pyelonephritis and Bronchitis, were found to have arisen out of or were aggravated by his employment.