Facts:

The case involves Baldomero Aribon as the petitioner against the Workmen's Compensation Commission and Canlubang Sugar Estate, C.J. Yulo and Sons as respondents. The events leading to the case began in 1957 when Aribon, a 39-year-old field worker, was employed by the respondent company. His work involved plowing fields, planting sugar cane, and cutting grass, for which he received a daily wage of P4.50, totaling P32.62 weekly. In 1967, Aribon began experiencing stomach pains and was diagnosed with a peptic ulcer after consulting the company's hospital. Despite receiving treatment, his condition worsened, leading him to stop working on November 15, 1967, upon the recommendation of Dr. Bunye.

On March 10, 1975, Aribon filed a claim for disability benefits under the Workmen's Compensation Act, asserting that his illness was work-related. Initially, the Workmen's Compensation Unit of Lucena City ruled in his favor, awarding him P6,000 in compensation. However, ...

Facts:

Background of the Claimant and Employment

• Claimant Baldomero Aribon, aged 39, was employed as a field worker by the respondent company since 1957.
• His daily work involved plowing fields, planting sugar cane, and cutting grass, for which he received a daily wage of P4.50 (approximately P32.62 per week).

Onset and Development of Illness

• In 1967, the petitioner experienced stomach pains and sought consultation at the respondent’s Canlubang Hospital.
• He was diagnosed with peptic ulcer by both the company doctor and other consulting physicians, and was placed on medication.
• Despite initial treatment, his condition recurred, leading him to cease work on November 15, 1967, and retire following the recommendation of Dr. Bunye.

Filing of the Claim and Decision by the Benefits Unit

• On March 10, 1975, the petitioner filed a claim for disability benefits under the Workmen’s Compensation Act (as amended), alleging that his illness arose from employment.
• Acting Referee Salvador C. Guevarra rendered a decision awarding disability benefits based on:
• Computation of 60% of his average weekly wage (P32.62), resulting in an amount that reached the statutory maximum of P6,000 despite calculations suggesting a higher sum.
• An administrative fee of P61.00 and attorney’s fees of P300.00 were similarly directed.

Respondent’s Appeal to the Commission

• The respondent company appealed the Acting Referee’s decision, challenging both the medical and procedural aspects.
• The respondent cited conflicting medical evaluations: one indicating Temporary Total Disability for 65.1 weeks (from March 15, 1967, to June 15, 1968) and another showing only a brief medical treatment period (from August 15, 1967, to November 15, 1967).
• They contended that the petitioner’s failure to submit a GI series test—a diagnostic procedure using barium to examine the upper gastrointestinal tract—was critical, arguing that without this test the claim could not be substantiated.
• The respondent further argued that even if the claim were otherwise proper, the computation of benefits was erroneous, as the disability period allegedly would warrant a much lower compensation than P6,000.00.

Procedural and Notice Irregularities

• The respondent asserted that the decision of the Workmen’s Compensation Commission was already final, noting that proper notice had been given to the petitioner and his counsel via copies of the decision.
• In examining evidentiary documents such as registry return receipts and a certification from the Department of Labor, the Court observed discrepancies:
• The registry return receipts for the petitioner’s counsel lacked a number, postmark, and differed in handwriting, casting doubt on the adequacy of actual service.
• This irregularity raised a serious issue regarding whether the petitioner truly received notice, a factor crucial to the finality of the decision.
• The case was processed during a transitional period when the Workmen’s Compensation Commission was winding up its functions due to a heavy backlog, contributing to the confusion in procedural requirements regarding notice.

Medical Evidence and the Legal Presumption

• Despite the absence of a GI series test, multiple physicians, including the company doctor, unequivocally diagnosed peptic ulcer based on clinical examination.
• The petitioner’s claim rested on the well-established presumption under the old Workmen’s Compensation Act that an illness arising during employment is presumed compensable, with the burden on the employer to rebut the connection.
• The petitioner, who found himself in a state of poverty following early retirement, lost contact with his counsel and remained unaware of the Commission’s decision due to the defective notice process.

Issue:

Notice and Procedural Regularity

• Was the petitioner properly notified of the Commission’s decision given the discrepancies in the registry return receipts and mailing records?
• Does the failure to effectuate proper notice affect the finality of the Commission’s decision and the petitioner’s right to appeal?

Sufficiency and Admissibility of Medical Evidence

• Is the clinical evidence presented by multiple attending physicians sufficient to establish the diagnosis of peptic ulcer in the absence of a GI series test?
• Does the statutory requirement for a GI series test constitute an absolute condition for compensability under the Workmen’s Compensation Act?

Computation and Award of Benefits

• Was the computation of disability benefits, specifically the awarding of the maximum sum of P6,000.00, correct given the disability period and the petitioner’s average weekly wage?
• Is the petitioner entitled to additional fees such as attorney’s fees and administrative fees under the circumstances, or should modifications be made?

Application of the Legal Presumption of Compensability

• Does the burden of proof to rebut the presumption that the illness is work-related lie with the employer, and was this burden met by the respondent?
• Should the inherent policy favoring compensability in cases of employment-related illness override procedural technicalities?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)