Title
Canete vs. Insular Lumber Co., Inc.
Case
G.R. No. 42175
Decision Date
Jul 10, 1935
Carpenter Jacinto Canete injured at work, losing fingers; court awarded compensation for temporary and permanent disabilities, ruling claim timely, injury work-related, and lump-sum payment due to employer's delay.
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Case Digest (G.R. No. 42175)

Facts:

  1. Employment Details:

    • The plaintiff, Jacinto Canete, was a carpenter employed by the defendant, Insular Lumber Co., Inc., for six years.
    • At the time of the accident, his salary was ₱2 per day, equivalent to ₱12 per week.
    • His work involved making wood patterns used in the foundry department of the defendant's sawmill.
  2. The Accident:

    • On March 13, 1931, while using an electric planing machine in the foundry, a piece of wood slipped from Canete's hand.
    • His right hand came into contact with the sharp edge of the machine, resulting in the loss of his thumb, first finger, and the first phalange of his middle finger.
  3. Legal Action:

    • Canete filed a claim for compensation under Act No. 3428 (Workmen's Compensation Act), as amended by Act No. 3812.
    • The trial court awarded him ₱6 weekly for 82½ weeks as compensation for permanent partial disability.
  4. Appeals:

    • Both parties appealed the decision.
    • The defendant contested the timeliness of the claim and argued that the injury was caused by Canete's negligence.
    • The plaintiff argued that he was entitled to additional compensation for temporary total disability under Section 14 of the Act.

Issue:

  • (Unlock)

Ruling:

  • (Unlock)

Ratio:

  1. Timeliness of Claims:

    • The mailing date of a claim, as shown by the post-office registry receipt, is considered the filing date for purposes of compliance with statutory deadlines.
  2. Compensation for Multiple Disabilities:

    • An injured employee is entitled to compensation for both temporary total disability and permanent partial disability if the injury results in both conditions.
    • Temporary total disability compensates for lost earnings during the healing period, while permanent partial disability compensates for the actual loss of a body member.
  3. Lump-Sum Payment:

    • Under Section 22 of the Workmen's Compensation Act, an employer's failure to pay compensation promptly entitles the employee to demand the entire balance in a lump sum.
  4. Legislative Intent:

    • The Workmen's Compensation Act is designed to provide fair and comprehensive compensation for injured workers, covering all forms of disability resulting from workplace injuries.


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