Facts:

In the case of Eustaquio Alejandro vs. Workmen's Compensation Commission, Republic of the Philippines, G.R. No. L-42595, decided on December 18, 1979, the petitioner, Eustaquio Alejandro, filed a compensation claim with the Workmen's Compensation Unit on January 15, 1973, for an injury sustained on September 16, 1969, while working on the Virac-Calolbon Road. He reported that he experienced a "Truma -Vitreous Hemorrhage" in his left eye and notified his employer of the injury, although he did not specify when or to whom notification was made. Alejandro ceased to work on September 19, 1969, and retired from government service the very next day at the age of 65, after approximately 28 years of employment as a Timekeeper and later as Maintenance Capataz with the Bureau of Public Highways.

The incident occurred when droplets of hot asphalt struck his left eye while he was supervising road work. Alejandro sought medical treatment the same day at the Zantua Medical C

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Facts:

Accident and Injury Details

• On September 16, 1969, while supervising the asphalting of the Palta-Palawig-Calolbon road in Virac, Catanduanes, petitioner Eustaquio Alejandro sustained an injury when droplets of hot asphalt struck his left eye.
• The injury was characterized as a traumatic incident leading to a vitreous hemorrhage, complicated by the petitioner’s pre-existing high blood pressure.
• Immediately following the accident, petitioner received emergency treatment at the Zantua Medical Clinic in Virac, Catanduanes, where Dr. Antonio Zantua attended to him by cleansing the affected orbital area and subsequently provided further care as the petitioner complained of progressive blurring of vision.
• A subsequent referral to a Medical Rating Officer, Dr. Vicente Ramirez of the Workmen’s Compensation Unit in Naga City, resulted in a certification that indicated:
• A temporary total disability for three months; and
• A permanent total disability for the complete loss of use of the left eye.

Employment and Claim Filing

• Petitioner, a long-time employee of the Bureau of Public Highways with approximately 28 years of service, held positions ranging from Timekeeper to Maintenance Capataz at the time of his injury.
• He retired on September 20, 1969, just four days after the accident, upon reaching the compulsory retirement age of 65, which became a critical fact in the evaluation of his temporary disability claim.
• On January 15, 1973, petitioner filed a compensation claim with the Workmen’s Compensation Unit, detailing the accident, the nature of his injury, and providing supporting documentary evidence, including medical certificates and reports.

Proceedings and Controversions

• The claim was initially set for hearing, but due to the respondent employer’s nonappearance (despite proper notice), petitioner’s evidence was received ex parte on August 17, 1973.
• On January 6, 1975, the Acting Referee rendered a decision awarding:
• Temporary total disability benefits under Section 14 amounting to P396.00 (covering 3 months of disability based on 60% of the petitioner’s weekly wage);
• Permanent disability benefits under Section 18 (alternatively referenced as Section 17 in some parts) totaling P2,777.00 for the loss of use of the left eye; and
• Reimbursement for medical expenses initially claimed at P5,755.00 but later reduced to P500.00, as well as attorney’s fees and administrative fees.
• The employer, through its Provincial District Engineer and the Solicitor General (filing on March 7, 1973), contended that:
• The injury did not arise out of and in the course of employment; and
• The petitioner continued working until his compulsory retirement, thereby negating any claim for wage loss and temporary disability benefits under Section 14.
• The respondent Commission, in its December 18, 1975 decision, reversed the Acting Referee’s award on the ground that there was no effective showing that petitioner was disabled by the injury—arguing he stopped working due to age rather than disability.

Evidentiary and Procedural Considerations

• Key evidence supporting petitioner’s claim included:
• The immediate treatment provided by Dr. Zantua, including his certificate noting the presence of asphalt and subsequent complications;
• The referral and report by Dr. Ramirez, which clearly established both temporary and permanent disabilities stemming from the injury; and
• The petitioner’s consistent testimony regarding the circumstances and effects of the injury.
• The employer’s reports and the Solicitor General’s controversion were challenged on the basis that they were filed beyond the statutory deadlines prescribed in Sections 37 and 45 of the Workmen’s Compensation Act, thereby undermining their effectiveness in disputing the petitioner’s claim.

Issue:

Whether petitioner’s injury sustained on September 16, 1969, while performing his work duties, qualifies as one arising out of and in the course of employment.

• Consideration of the factual and medical evidence establishing the causation between the work environment and the injury.

Whether the timing and manner of the employer’s controversion (filed by the Provincial District Engineer and the Solicitor General) effectively nullify petitioner’s claim for compensation.

• Assessment of the statutory deadlines (14 days from the occurrence or 10 days from knowledge of the injury) and the impact of the delayed filings.

Whether the award of benefits under the different provisions of the Workmen’s Compensation Act is justified, particularly:

• The temporary total disability benefits under Section 14—given that petitioner continued working until his compulsory retirement, thereby questioning the existence of wage loss.
• The permanent disability benefits for the complete loss of use of the left eye under Section 18 (or Section 17), based on the clear medical evidence.
• The medical reimbursement benefits under Section 13, which are independent of the wage loss argument.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)