Mendoza v. Enriquez Furniture
REITERATIONFacts
1. The Antecedents: Alberto Mendoza was employed as a driver by V. Enriquez Furniture in 1960, earning P5.00 daily. His work involved frequent deliveries six days a week, often leading to irregular meal times. In September 1962 and again in January 1963, Mendoza suffered from peptic ulcer and ascariasis, requiring hospitalization. Due to his frequent absences caused by illness, he was terminated from his employment in October 1963. 2. Procedural History: Following his termination, Mendoza initially filed a claim for separation and overtime pay, which was settled. He then filed a claim for compensation under the Workmen's Compensation Act for disability due to peptic ulcer and ascariasis, alleging he contracted these illnesses during his employment. The claim was dismissed by the Acting Chief Referee of the Department of Labor. After a motion for reconsideration was denied, Mendoza appealed to the Workmen's Compensation Commission (WCC). Mendoza died on July 26, 1967, and his widow was substituted as claimant. The WCC, through Associate Commissioner Priscilla Argonza Medina, denied the claim on May 26, 1970. A subsequent motion for reconsideration was denied by the WCC en banc on July 29, 1971. 3. The Petition: This petition was filed by Alberto Mendoza (later substituted by his widow) seeking review of the WCC en banc's July 29, 1971 order denying their motion for reconsideration. The petitioner raises two main issues: (1) whether the WCC en banc's order was in accordance with law, and (2) whether the claim for compensation is valid. The petition argues that Mendoza's illnesses, peptic ulcer and ascariasis, were aggravated by his working conditions and that under the Workmen's Compensation Act, the illness is presumed to have arisen out of employment, making the claim compensable. The petition was filed on October 10, 1971.
Issue(s)
Whether the claim for compensation is compensable under the Workmen's Compensation Act. Whether the order of the WCC en banc denying the motion for reconsideration is in accordance with law.
Ruling
The Supreme Court reversed and set aside the decision of the Workmen's Compensation Commission dated July 29, 1971. It ordered the private respondents to pay disability benefits to the petitioner, to be determined by the Employees' Compensation Commission, considering the petitioner's income during the period of disability, the present-day economic standard, and financial realities, with legal interest from October 10, 1971.
Ratio Decidendi
On the issue of compensability: The Court held that under Section 2 of the Workmen's Compensation Act (Act No. 3428), an employee suffering personal injury from an accident arising out of and in the course of employment, or contracting an illness directly caused by, aggravated by, or the result of the nature of such employment, is entitled to compensation. The Court noted that petitioner Mendoza was hospitalized twice due to peptic ulcer and related ailments, during which periods he was unable to render service due to physical inability. Disability, under the Act, is defined as a loss or diminution of earning power due to an injury arising out of and in the course of employment, not the injury itself. The Court found that Mendoza suffered disability by his sickness, which was compensable as it supervened during his employment and was aggravated by his working conditions, such as irregular meal times. The Court emphasized that under the old compensation law, the claimant was relieved of the duty to prove causation due to the legal presumption that the illness arose out of employment. The Court further clarified that for a case to fall under the old compensation law, the ailment must have been contracted prior to January 1, 1975, which was satisfied by Mendoza's hospitalizations in 1962 and 1963. Therefore, petitioner's right to compensation was clear. There was no ratio provided for the second issue, so this entry is left blank.
Main Doctrine
Under the Workmen's Compensation Act, disability is compensated when there is a loss or diminution of earning power due to sickness arising out of and in the course of employment. The law presumes that the illness arose out of employment, and the employer must provide compensation.