Facts:

The petitioner in this case is Bernardo Bambalan, an employee of Universal Textile Mills, Inc., where he had been working since May 2, 1972, as a machine operator at their plant located in Baranka, Marikina, Metro Manila. He earned a daily wage of Php 11.80 and worked six days a week. On March 26, 1975, Bambalan filed a claim for sickness benefits before the Workmen's Compensation Commission (WCC) due to an ailment diagnosed as "Pyelonephritis (kidney) acute, and Bronchitis, acute." He argued that these conditions either arose in the course of his employment or were aggravated by the nature of his work. The claim, designated as RO4-WC Case No. 7402, was initially dismissed by the WCC Unit Head due to the failure of both parties to appear at the scheduled hearing on September 25, 1975. When asked for reconsideration, Bambalan's motion was denied, but records were later forwarded to the WCC for a review. The WCC upheld the dismissal of his claim, citing insuffici

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Facts:

Employment and Claim Background

• Bernardo Bambalan was employed as a machine operator by Universal Textile Mills, Inc. since May 2, 1972, working six days a week and earning a daily wage of P11.80.
• On March 26, 1975, he filed a claim for sickness benefits before the Workmen's Compensation Commission (WCC) for the ailments "Pyelonephritis (kidney) acute and Bronchitis, acute" which he alleged were suffered in the course of his employment or were aggravated by it.

Proceedings at the Workmen's Compensation Commission

• The claim, docketed as RO4-WC Case No. 7402, was initially dismissed by the WCC Unit Head due to the nonappearance of parties at a scheduled hearing on September 25, 1975.
• Bambalan sought reconsideration of the dismissal, but the motion was denied.
• The case records were forwarded to the WCC for review in accordance with Section 4, Rule 15 of the Rules of the WCC.
• On review, the WCC affirmed the dismissal of the claim on the basis that there was insufficient substantial evidence to warrant its allowance and that the alleged ailment had no causal relation with the nature of his employment.

Evidence Submitted and Supporting Documentation

• Notice of Injury or Sickness and Claim for Compensation, which detailed:
• Jurisdictional facts including weekly salary of P70.80, the nature of the illness, and dates of work interruption and resumption.
• Identification of the attending physician (Dr. Manuel Belarmino of Ortanez University Hospital).
• Physician's Report by Dr. Manuel Belarmino confirming the diagnosis (Pyelonephritis Acute and Bronchitis Acute), including periods of compensability.
• An Affidavit of the Claimant revealing:
• His hard work and the poor working conditions at the factory.
• Continuous work despite the onset of his ailments.
• Specific dates of confinement and treatment at the company’s medical department.
• Timely notification to the employer and the employer’s failure to controvert his claim.
• Medical certificates corroborating the diagnosis and corresponding confinement periods.
• An Affidavit from a co-worker serving as corroborative evidence.

Allegations and Arguments by the Petitioner

• The petitioner contended that the documents and evidence submitted were ample to secure his claim for compensation.
• He argued that the WCC improperly dismissed his claim by rejecting the documentary evidence on the unjustified basis that they lacked the necessary elements to be given due credence from their face value.
• He further asserted that the respondent company failed to timely controvert his claim as required under the applicable provisions of the Workmen's Compensation Act.

Issue:

Sufficiency and Admissibility of Documentary Evidence

• Whether the submitted documents (Notice of Injury, Physician's Report, Affidavits, and Medical Certificates) were sufficient and admissible under the relaxed evidentiary rules applicable to workmen's compensation cases.

Causal Connection Between Employment and Ailments

• Whether the petitioner's ailments—Pyelonephritis Acute and Bronchitis Acute—arose out of or were aggravated by the nature of his employment.
• Whether the causal relation established by the facts and supportive evidence was sufficient to warrant compensation.

Failure to Controvert the Claim

• Whether the respondent company's failure to timely controvert the petitioner's claim constituted a basis for granting an outright award of compensation without the need for further hearing.

Application of the Workmen's Compensation Act and Evidentiary Rules

• Whether the strict rules of technical evidence and legal forms are applicable in the context of workmen's compensation cases or whether they should be relaxed in light of the governing provisions and previous jurisprudence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)