De la Rosa v. Philippine National Railways
REITERATIONFacts
The Antecedents: Petitioner Manuel de la Rosa retired as freight clerk and checker of respondent Philippine National Railways (PNR) on January 16, 1975. He filed a compensation claim on March 26, 1975, for disability benefits under Act 3428, otherwise known as the Workmen's Compensation Act. The defunct Workmen's Compensation Commission awarded him P3,830.19 as disability compensation and P39.00 as administrative fee. Procedural History: Writs of execution were issued but could not be enforced due to PNR's representation that enforcement would be premature pending its petition for review. On January 5, 1978, the Secretary of Labor dismissed the claim, ruling that the disability commenced on January 16, 1975, when the Labor Code was already in effect, thus divesting the Acting Referee of jurisdiction under Act 3428. The Petition: Petitioner argues that his disability, pulmonary tuberculosis, was contracted on October 10, 1968, more than six years before his retirement, and that the Secretary of Labor erred in finding otherwise. PNR counters that the Acting Referee lacked jurisdiction because the disease commenced when the Labor Code was in effect, abolishing the Workmen's Compensation Act.
Issue(s)
Whether the Secretary of Labor erred in finding that the petitioner's disability commenced on January 16, 1975. Whether the Acting Referee of the Workmen's Compensation Commission had jurisdiction to hear and decide the case. Whether the petitioner's illness, pulmonary tuberculosis, is an occupational or work-connected disease. Whether the respondent PNR failed to controvert the petitioner's claim for compensation within the reglementary period.
Ruling
The petition is granted. The order of the Secretary of Labor dated January 5, 1978, is reversed. The Employees' Compensation Commission is directed to enforce the writ of execution against the respondent Philippine National Railways pursuant to the decision of the Acting Referee dated November 13, 1975.
Ratio Decidendi
On whether the Secretary of Labor erred in finding that the petitioner's disability commenced on January 16, 1975: The Court ruled in favor of the petitioner. Contrary to the Secretary of Labor's pronouncement, the records and petitioner's exhibits, particularly his notice of sickness, indubitably show that he was afflicted with pulmonary tuberculosis as early as October 10, 1968. This fact was corroborated by Dr. Antonio D. Raneses, who stated in his Physician's Report that he first administered treatment on September 8, 1974, and continued treatment thereafter. Therefore, the ailment supervened before January 1, 1975, the effectivity date of Titles II and III of Book IV of the New Labor Code. On whether the Acting Referee of the Workmen's Compensation Commission had jurisdiction to hear and decide the case: The Court held that the Acting Referee had jurisdiction. Although the claim was filed on March 26, 1975, the illness was contracted on October 10, 1968. The governing law in workmen's compensation cases is determined by the date on which the claimant contracted his illness. Since the illness predated the effectivity of the New Labor Code, the claim correctly falls under the purview of the Workmen's Compensation Act, and the Acting Referee acted with authority. On whether the petitioner's illness, pulmonary tuberculosis, is an occupational or work-connected disease: The Court affirmed that tuberculosis is an occupational or work-connected disease in certain occupations, including that of a freight clerk and checker. The Court noted that tuberculosis is an ailment latent in man, which can become active under favorable conditions such as excessive physical exertion without rest, exposure to extreme temperatures, poor nutrition, and contact with infected individuals. Considering the nature of petitioner's employment, which involved too much physical exertion and exposure to the elements, and the fact that his illness supervened during his employment, it was concluded that the illness arose out of, or was at least aggravated by, his work, making it compensable. On whether the respondent PNR failed to controvert the petitioner's claim for compensation within the reglementary period: The Court found that respondent PNR failed to avail itself of its right to controvert the claim. The records showed a total absence of controversion. Under Section 45 of Act 3428, as amended, an employer must file a notice of controversion within ten days after knowledge of the alleged accident or within fourteen days of disability. Failure to controvert within the reglementary period is fatal and renders the claim compensable and its reasonableness and validity beyond challenge.
Main Doctrine
The governing law in workmen's compensation cases is determined by the date the claimant contracted the illness, and failure of the employer to controvert the claim within the reglementary period renders the claim compensable and its validity beyond challenge.