Title
Arzadon vs. Workmen's Compensation Commission
Case
G.R. No. L-42404
Decision Date
Dec 8, 1976
A public school teacher filed a workmen's compensation claim for tuberculosis. Despite procedural flaws, the Supreme Court upheld her award, emphasizing liberal construction of labor laws and presumption of compensability.
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Case Digest (G.R. No. L-42404)

Facts:

  1. Filing of the Claim:

    • On March 12, 1975, Agripina Arzadon, a public school teacher, filed a Workmen's Compensation claim with the Department of Labor, Regional Office No. 1, Dagupan City, against the Republic of the Philippines (Bureau of Public Schools).
    • She submitted a physician's report (Annex B) signed by Dr. Abraham Gorospe, diagnosing her with "PTB, moderately advanced" (pulmonary tuberculosis).
  2. Notice to Respondent:

    • On March 26, 1975, the Acting Chief of the Workmen's Compensation Section sent a notice of the claim and the physician's report to the respondent through the Office of the Solicitor General, requiring a reply within ten (10) days.
    • The respondent failed to reply within the stipulated period.
  3. Letter-Award by Regional Office:

    • On May 27, 1975, the Acting Chief of Regional Office No. 1 rendered a letter-award of P6,000.00 in favor of Arzadon due to the respondent's failure to respond.
  4. Motion to Set Aside Award:

    • On June 17, 1975, the Office of the Solicitor General filed a motion to set aside the award and/or elevate the case to the Workmen's Compensation Commission.
    • The motion was denied on June 24, 1975, and the case records were forwarded to the Commission.
  5. Decision of the Workmen's Compensation Commission:

    • On December 26, 1975, the Commission reversed the letter-award, citing that the respondent was not properly furnished with the notice and claim.
    • The Commission also noted that the physician's report was unverified and lacked supporting evidence, such as a chest x-ray, to confirm the diagnosis of tuberculosis.
  6. Petitioner's Employment and Illness:

    • Arzadon was employed as a public school teacher with a salary of P403.70.
    • She stopped working on September 24, 1974, at the age of 62, after 42.5 years of service, due to pulmonary tuberculosis.
    • Her duties as a teacher, including standing for long hours and preparing lesson plans, allegedly weakened her resistance, predisposing her to tuberculosis.

Issue:

  1. Whether the Workmen's Compensation Commission erred in reversing the letter-award granted to Arzadon.
  2. Whether the unverified physician's report and lack of additional evidence (e.g., chest x-ray) justified the denial of the claim.
  3. Whether the respondent's failure to reply to the claim within ten (10) days constituted a waiver of its defenses.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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