Fernandez v. Anscor Container Corporation
REITERATIONFacts
The Antecedents: Petitioner Jesus Fernandez was employed by respondent Anscor Container Corporation for over twenty-three years as a maintenance mechanic assigned to Quality Control. He took sick leave on June 13, 1974, after a medical examination revealed advanced Bilateral PTB, with a subsequent examination on December 2, 1974, diagnosing him with "Far Advanced PTB." Petitioner filed a claim for Workmen's Compensation Commission (WCC) benefits on March 4, 1975. Procedural History: The WCC Regional Office initially granted compensation benefits, including accrued compensation, weekly compensation, and medical services, based on the finding that the petitioner contracted PTB in the course of employment, aggravated by his work, and that the respondent's failure to dispute the claim constituted an admission of compensability. However, the WCC, upon appeal by the respondent corporation, set aside the award and dismissed the case due to insufficient evidence, specifically finding no categorical proof that the petitioner was suffering from PTB on June 13, 1974, when he ceased working. The Petition: The instant petition seeks to review the decision of the Workmen's Compensation Commission which denied the claim for disability benefits.
Issue(s)
Whether the Workmen's Compensation Commission erred in dismissing the claim for disability benefits. Whether the petitioner's illness of pulmonary tuberculosis was contracted or aggravated during his employment with the respondent corporation. Whether the presumption of compensability applies in this case.
Ruling
The decision of the Workmen's Compensation Commission dismissing the claim for compensation is REVERSED and SET ASIDE. The decision rendered by the Workmen's Compensation Section, Manila is REINSTATED but MODIFIED. The private respondent shall pay petitioner Jesus Fernandez the sum of SIX THOUSAND PESOS (P6,000.00) pursuant to the provision of the Workmen's Compensation Act, as amended; the petitioner's counsel of record the sum of SIX HUNDRED PESOS (P600.00) in accordance with Rule 27 of the Rules of the Workmen's Compensation Commission as attorney's fees; and the sum of SIXTY SIX PESOS (P66.00) to the Department of Labor and Employment.
Ratio Decidendi
On the issue of whether the Workmen's Compensation Commission erred in dismissing the claim for disability benefits: The Supreme Court found merit in the petition, reversing the WCC's decision. The Court noted that the respondent corporation failed to present evidence to prove its allegation that the disabling condition was not due to an illness directly caused or aggravated by the nature of employment. Contrary to the WCC's findings, the petitioner was diagnosed with pulmonary tuberculosis (PTB Far Advanced) as of June 13, 1974, by the corporation's own physician, Dr. Herminio Ilagan, on the same day the petitioner filed his sick leave. Subsequent X-rays showed improvement, but the initial diagnosis by the company physician established the onset of the illness during employment. The Court emphasized that the WCC's reversal was based on a misapprehension of the evidence, particularly the company physician's report. On the issue of whether the petitioner's illness of pulmonary tuberculosis was contracted or aggravated during his employment with the respondent corporation: The Court found that the petitioner's sickness had its onset or was at least aggravated during his employment. The diagnosis by the company physician on June 13, 1974, coinciding with the petitioner's sick leave, was a crucial piece of evidence. Furthermore, the physician's report by Dr. Alfredo P. Del Rosario explicitly stated that the petitioner was suffering from Far Advanced PTB "due to the nature of his work rendering overtime." This report, coupled with the timeline of medical examinations and the petitioner's prolonged treatment, supported the conclusion that the illness was work-related or aggravated by his employment. On the issue of whether the presumption of compensability applies in this case: The Supreme Court reiterated the principle of presumption of compensability under the Workmen's Compensation Act, as amended, citing Barbas v. Victorias Milling Co., Inc.. Given that the illness was diagnosed during employment and there was no dispute that the Workmen's Compensation Act applied, the presumption that the illness arose out of and in the course of employment attached. The burden was on the employer to overcome this presumption, which it failed to do. The Court also invoked the rule on aggravation under the former law, as seen in Santarin v. Employees' Compensation Commission, further strengthening the claim for compensation.
Main Doctrine
The Supreme Court reversed and set aside the decision of the Workmen's Compensation Commission dismissing the claim for compensation, reinstating and modifying the award granted by the Regional Office, holding that the illness of pulmonary tuberculosis was contracted or aggravated during employment and that the presumption of compensability applies.