Case Digest (G.R. No. L-43647)
Facts:
Eustaquio Barbas, the claimant-petitioner, was employed by Victorias Milling Company, Inc. from 1947 until his retirement on September 30, 1971, at the age of fifty-five. On August 22, 1972, Barbas filed a claim for disability benefits under the Workmen's Compensation Act, asserting that he contracted pulmonary tuberculosis (PTB) during his employment. An x-ray and physical examination conducted on October 2, 1975, revealed that he was suffering from minimal PTB, leading the Workmen's Compensation Unit in Bacolod City to award him temporary partial disability benefits. The award included provisions for medical services and a monetary compensation of P895.56 for his 12% disability rating.
Barbas contested the amount of the award, believing he was entitled to greater compensation under Section 14 of the Workmen's Compensation Act. He subsequently appealed to the Workmen's Compensation Commission, which reversed the Bacolod office's decision, dismissing hi...
Case Digest (G.R. No. L-43647)
Facts:
Employment Background:
- Eustaquio Barbas was employed by Victorias Milling Company from 1947 until his retirement on September 30, 1971, at the age of 55. He worked as a track capataz.
Claim for Disability Benefits:
- On August 22, 1972, Barbas filed a claim for disability benefits under the Workmen's Compensation Act, alleging that he contracted pulmonary tuberculosis (PTB) in 1969 while still employed by the company.
Medical Evidence:
- In November 1969, Barbas took a sick leave and was confined at St. Joseph's Hospital for PTB treatment. The company's physicians, Dr. Jara and Dr. Dungo, confirmed his condition through x-rays and examinations. The company also paid for his medicines.
- On October 2, 1975, an x-ray test conducted by the Workmen's Compensation Unit in Bacolod City revealed that Barbas was suffering from PTB Minimal, with a 12% disability evaluation under Section 18 of the Workmen's Compensation Act.
Initial Decision by Workmen's Compensation Unit:
- The Bacolod office awarded Barbas temporary partial disability benefits, including P895.56 for 12% N.S.D., attorney's fees of P44.78, and a P9.00 contribution to the Workmen's Compensation Fund.
Appeal to Workmen's Compensation Commission:
- Barbas appealed the award, believing he was entitled to higher compensation under Section 14 of the Act. However, the Commission dismissed his claim, ruling that he failed to prove his illness was work-related. The Commission relied on an x-ray taken on September 19, 1972, after his retirement, as the sole evidence.
Additional Evidence Submitted:
- Barbas submitted the following evidence:
- Exh. A: X-ray report by Dr. Amador Antonio confirming PTB.
- Exh. B: Affidavit detailing how he contracted PTB during employment.
- Exh. C: Certificate of Appreciation for 26 years of service.
- Exh. D: Sick leave form dated November 17, 1969, showing his hospitalization for PTB.
- Barbas submitted the following evidence:
Forced Retirement:
- Barbas retired at 55, earlier than the standard retirement age, due to his deteriorating health caused by PTB.
Issue:
- Whether Eustaquio Barbas is entitled to disability benefits under the Workmen's Compensation Act.
- Whether the Workmen's Compensation Commission erred in dismissing his claim based on insufficient evidence of work-related illness.
Ruling:
The Supreme Court reversed the decision of the Workmen's Compensation Commission and reinstated the decision of the Workmen's Compensation Unit in Bacolod City, with modifications. The Court ruled that:
- Barbas is entitled to disability benefits under the Workmen's Compensation Act.
- The maximum compensation of P6,000.00 under Section 14 of the Act is awarded to Barbas.
- Attorney's fees of P600.00 and P66.00 to the Ministry of Labor and Employment are also awarded.
Ratio:
Presumption of Compensability:
- Under the Workmen's Compensation Act, there is a presumption that an illness contracted during employment is work-related. Barbas was in good health when he started working and contracted PTB during his employment. The company did not rebut this presumption.
Evidence of Work-Related Illness:
- The sick leave form (Exh. D) and affidavit (Exh. B) proved that Barbas was diagnosed with PTB in 1969 while still employed. The company's physicians confirmed his condition, and the company paid for his treatment.
Forced Retirement Due to Illness:
- Barbas retired at 55 due to his deteriorating health, which was directly linked to his PTB. This constitutes total temporary disability under the Act.
Equitable Considerations:
- Given Barbas's age and the progression of his illness, the Court found it equitable to award the maximum compensation of P6,000.00 under Section 14 of the Act.