Facts:

The case involves Abundio Alburan as the petitioner and the Republic of the Philippines, specifically the Department of Health, as the respondent. The events leading to this case began when Alburan was employed as a driver for the Department of Health at Malaria Unit No. C-17 in Catbalogan, Samar, starting February 15, 1955, earning a daily wage of P14.66. On May 19, 1973, he experienced health issues, including difficulty urinating, dizziness, severe headaches, and general body weakness. His physician, Dr. Modesto Villarin, Jr., diagnosed him with "Glomerulonephritis Hypertension (Essential) Rheumatoid Arthritis" and indicated that these conditions were aggravated by his work as a driver, which exposed him to various physical and environmental stresses.

Alburan had taken several sick leaves throughout his employment, including periods in 1959 and 1973. In June 1974, he filed a notice of sickness and a claim for compensation benefits with the Workmen's Compens...

Facts:

Employment and Work Environment

• Petitioner, Abundio Alburan, was employed by the Department of Health as a driver since February 15, 1955 at the Malaria Unit No. C-17 in Catbalogan, Samar.
• He earned a daily wage of P14.66 (with an average weekly wage of P98.62).
• His work required extensive travel in adverse conditions, exposing him to physical, mental, and environmental hardships.

Medical Condition and Sick Leaves

• On May 19, 1973, petitioner sought medical attention due to symptoms that included difficulty in urination, dizziness, severe headache, and general body weakness.
• His attending physician, Dr. Modesto Villarin, Jr., diagnosed him with “Glomerulonephritis, Hypertension (Essential), Rheumatoid Arthritis – Guarded,” attributing the condition to, and its aggravation by, his employment as a driver.
• The records indicate several periods of sick leave taken by petitioner:
• January 15–31, 1959 (16 days)
• February 19–April 31, 1959 (67 days)
• May 19–August 31, 1973 (105 days)
• September 1–October 31, 1973 (61 days)

Filing and Processing of the Claim

• In June 1974, petitioner filed his notice of sickness and claim for compensation benefits with the Workmen’s Compensation Unit of Regional Office No. 4, Department of Labor, Manila, which was docketed as R04-WC Case No. 154362.
• On July 10, 1974, petitioner’s counsel filed an ex-parte motion to set the case for hearing, arguing that both parties should be given the opportunity to present evidence.
• The Office of the Solicitor General, representing the respondent, registered its controversion to the claim on July 24, 1974.

Submission of Supporting Evidence

• In early 1975, petitioner sent several documents in support of his claim:
• Summary Report of the Circumstances of Illness prepared and signed by Officer-in-Charge Pablito M. Flores dated March 3, 1975.
• Physician’s Report of Sickness dated February 26, 1975, issued by Dr. Modesto Villarin, Jr.
• Later, petitioner submitted additional evidence:
• Certificate of Attending Physician, signed and dated November 2, 1975.
• Despite his efforts, the records of R04-WC Case No. 154362 were not found in the Regional Office, prompting him to file another claim with Regional Office No. 9 on August 20, 1975, which was subsequently dismissed on September 15, 1975 due to his pending claim in Manila.

Administrative and Procedural Developments

• As early as January 15, 1975, Acting Referee Estratonico S. Anano of Regional Office No. 4 issued an order dismissing petitioner’s claim due to the lack of required documents, without affording him a proper hearing on the merits.
• On January 14, 1976, the Workmen’s Compensation Section denied petitioner’s motion for reconsideration and elevated the entire case records to the Workmen’s Compensation Commission for review.
• On January 26, 1976, the Commission affirmed the earlier dismissal, stating that the records showed no supporting evidence establishing the illnesses, particularly their work-connection.

Allegations of Denial of Due Process

• Petitioner contended that the dismissal of his claim violated his right to due process, noting:
• The initial dismissal order was issued without a hearing on the merits.
• He did not receive notice of any scheduled hearing despite the motion for hearing being filed.
• The subsequent motions for reconsideration and the additional dismissal order (dated March 12, 1976) further deprived him of the opportunity to present his evidence.
• Petitioner argued that his repeated submissions of supportive evidence were overlooked, and administrative irregularities compounded the denial of due process.

Relief Sought by Petitioner

• Petitioner sought sickness benefits and disability compensation under the Workmen’s Compensation Act, asserting that his sickness was work-related and aggravated by his employment conditions.
• He claimed entitlement to:
• Disability compensation amounting to P6,000.00.
• Reimbursement of medical and hospital expenses upon presentation of proper receipts.
• Attorney’s fees equivalent to 10% of the recoverable amount.
• Administrative fees and other rehabilitative services as needed, although the latter relief (provision of services, appliances, and supplies) was not enforced due to lack of unanimity among the judges.

Issue:

• Whether petitioner’s due process rights were violated by dismissing his claim without affording him a proper hearing on the merits.
• Whether the dismissal of the claim solely on the basis of the alleged absence of required documents was justified despite petitioner’s continuous efforts and submission of supportive evidence.
• Whether petitioner is entitled to sickness and disability compensation under the Workmen’s Compensation Act, considering the work-related nature of his diagnosed illnesses.
• Whether the procedural irregularities, including the lost records and the failure to consolidate all evidence, amounted to a grave abuse of discretion on the part of the Workmen’s Compensation Commission.
• How the doctrine of presumed compensability should be applied in reviewing the evidentiary record when an employee’s claim of work-related illness is uncontradicted by substantial evidence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)