Title
Blanco vs. Workmen's Compensation Commission
Case
G.R. No. L-21385-86
Decision Date
Aug 22, 1969
A logging truck accident led to deaths, prompting claims under the Workmen’s Compensation Act. The Supreme Court upheld compensation, affirming employer-employee ties and rejecting prescription defenses.
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Case Digest (G.R. No. L-21385-86)

Facts:

Background of the Case

  • The case involves an appeal from a decision of the Workmen's Compensation Commission in WC cases Nos. RO-1-981 and RO-1-1010-A.
  • The petitioner, Crispiniano Blanco, was engaged in the logging business since 1948 and owned a six-by-six truck involved in a fatal accident on June 18, 1956, in Masinloc, Zambales.
  • The truck, loaded with logs and carrying six men, overturned, resulting in the deaths of four individuals: Tomas Dragon, Diomedes Basa, Antonio Panis, and Wilfredo de la Cruz. Two others, Amador Macaspac (the driver) and Dominador Domulot, survived.

Employment and Compensation Details

  • The deceased Tomas Dragon and Diomedes Basa were employed by Blanco as woodcutters and were on the truck under his orders to assist in delivering logs.
  • Dragon and Basa earned an average weekly wage of P50.00, in addition to food and cigarettes.
  • Dragon was survived by his parents, Sebastian Dragon and Bonifacia Dumlao, who were wholly dependent on him for support. Basa was survived by his wife, Erlinda Domulot, and daughter Remedios, who were also dependent on him.

Payments and Claims

  • After the accident, Blanco paid P500.00 to Erlinda Domulot (Basa’s widow) and P500.00 to Sebastian Dragon (Tomas Dragon’s father) and Rosario Dragon (Wilfredo de la Cruz’s widow). These payments were allegedly made to dismiss charges against the driver, Macaspac.
  • Despite these payments, Sebastian Dragon and Erlinda Domulot filed claims for death compensation under the Workmen’s Compensation Act.

Initial Decisions and Appeals

  • The claims were initially denied by Hearing Officers Pedro A. de Leon and Hipolito H. Nagui, who ruled that the claimants failed to prove an employer-employee relationship between Blanco and the deceased.
  • The claimants appealed to the Workmen’s Compensation Commission, which reversed the decisions and awarded compensation, including death benefits, burial expenses, and attorney’s fees.
  • Blanco filed a Petition for Certiorari with the Supreme Court, raising several issues, including jurisdiction, prescription, hearsay evidence, and the existence of an employer-employee relationship.

Issue:

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Ruling:

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Ratio:

  1. Jurisdiction: The Commission had jurisdiction to decide the case despite the alleged withdrawal of the petitions for review, as the withdrawal was not validly executed and was obtained through fraud.
  2. Prescription: The defense of prescription cannot be raised for the first time on appeal and is deemed waived if not pleaded during the trial.
  3. Hearsay Evidence: While hearsay evidence was admitted, it was not the sole basis for the decision. Corroborating evidence, such as testimonies and payments made by Blanco, supported the findings.
  4. Employer-Employee Relationship: The Commission’s finding of an employer-employee relationship was supported by substantial evidence, including Blanco’s ownership of the truck, his logging business, and the testimonies of witnesses.
  5. Awards: The Commission’s awards for burial expenses and attorney’s fees were justified under the Workmen’s Compensation Act and related legal provisions, even if not explicitly demanded by the claimants.


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