G.R. No. 255750 - People vs. Argayan y Ognayon

The claimant, Joaquin Boo, was employed by Blue Bar Coconut Company since 1946 as a dryer man.
His work involved regulating the pressure and heat of a steam machine (dryer) used to desiccate coconut.
Part of his duties also included making rounds in the company compound to supervise subordinate workers.
Prior to his employment, Boo underwent a physical examination by the company’s physician and was deemed fit for service.
In April 1948, after an X-ray evaluation, he was insured by the Philippine American Life Insurance Company.

In 1948, while inspecting work near a motor, the claimant suffered an accident: he experienced an electric shock and sustained injuries from a running belt which cut his legs and caused multiple contusions.
For the 1948 accident, the company’s physician, Dr. Artemio Masangkay, treated him for about five months and the company compensated him with P600.
In October 1951, while at work, the claimant experienced haemoptysis (coughing blood), an indication of pulmonary tuberculosis, which led to his being laid off as he became disabled.
Subsequent to the onset of symptoms, he was referred by Dr. Masangkay to the Quezon Institute, where he underwent treatment from November 13, 1951, to March 1952.

Dr. Masangkay testified that the claimant’s duties exposed him to significant temperature fluctuations, which could lower his body resistance and predispose him to tuberculosis.
The physician also noted that the claimant’s night duties likely contributed to a lack of sleep, further aggravating his condition.
The diagnostic reports from both Dr. Masangkay and Dr. Bautista of the Quezon Institute confirmed a diagnosis of pulmonary tuberculosis with indicators of a moderately advanced stage.
It was inferred that even if the claimant had contracted the infection before employment, the aggravation of the illness was attributed to his work conditions at the factory.

Joaquin Boo filed a “Notice of Injury or Sickness and Claim Compensation” under the Workmen’s Compensation Act (Republic Act No. 772).
The Workmen’s Compensation Commission, upon hearing evidence from both parties, rendered a decision awarding him compensation along with continued weekly payments and medical treatment/hospitalization requirements.
The decision included orders for payments from both the Blue Bar Coconut Company and its insurance carrier, E. E. Elser, Inc.
A motion for review by the respondents led the Deputy Workmen’s Compensation Commissioner to reaffirm the referee’s decision. However, he excluded the insurance carrier from the liability, holding the company solely responsible while preserving its right of reimbursement from the carrier.

A petition was filed to set aside the decision on the ground that the Deputy Commissioner lacked jurisdiction, asserting that the exclusive jurisdiction over workmen’s claims resided with the Workmen’s Compensation Commissioner.
The contention was that the Act vested the exclusive authority with the Workmen’s Compensation Commission to hear and decide claims, thus removing the prior jurisdiction of the Justice of the Peace Courts and Courts of First Instance.

Whether the Deputy Workmen’s Compensation Commissioner had the jurisdiction to hear and decide claims under the Workmen’s Compensation Act.
Whether the “exclusive jurisdiction” granted to the Workmen’s Compensation Commission was intended to limit or include the Deputy Commissioner’s authority.

Whether the claimant’s pulmonary tuberculosis, manifested by the symptom of coughing blood, vis-à-vis the nature of his work in the factory, qualifies as a compensable disease under the Act.
Whether the appearance of the disease, even if latent prior to employment, becomes compensable if aggravated by the conditions inherent in the claimant’s work.

Whether the claimant’s disability, which became apparent in October 1951, should be considered under the provisions of the Workmen’s Compensation Act as originally enacted even though amendments (Republic Act No. 772) took effect on June 20, 1952.
How the timing of the claimant’s disability affects the employer's liability and the compensability of the sickness.