Facts:

The case involves Central Azucarera Don Pedro as the petitioner and the Workmen's Compensation Commission along with Pedro Villanueva as the respondents. The events leading to this case began when Pedro Villanueva commenced his employment with Central Azucarera Don Pedro in 1933 as a "palero" after successfully passing a pre-employment physical and medical examination. In 1939, he was promoted to "fogoner," a position he held until 1946 when he was elevated to "cabo palero," which he maintained until July 28, 1961. On that date, he ceased working due to various health issues, including fever, chest and back pains, body weakness, and coughing. Villanueva claimed that he had experienced these symptoms since 1943, and in 1959, he reported spitting blood while on duty. Despite periodic medical examinations and X-rays starting in 1952, which indicated he was in good health, he was eventually hospitalized from August 10 to September 2, 1961. On Nov...

Facts:

1. Employment History and Duties:

   • Pedro Villanueva began working with Central Azucarera Don Pedro in 1933 as a "palero" after passing a pre-employment medical examination.
   • In 1939, he was promoted to "fogonero" and later to "cabo palero" in 1946, a position he held until July 28, 1961, when he stopped working due to health issues.
   • His duties included cleaning furnaces, supervising workers, and ensuring the supply of water to boilers. He worked in shifts, including night shifts, and performed physically demanding tasks during both milling and off-milling seasons.

2. Health Issues and Medical History:

   • Villanueva began experiencing symptoms such as fever, chest and back pains, body weakness, and coughing as early as 1943. In 1959, he spat blood while working.
   • Periodic medical and X-ray examinations from 1952 onwards showed he was in good health and free from lung ailments. However, an X-ray on September 25, 1961, revealed minimal pulmonary tuberculosis, later confirmed by another X-ray on December 1, 1961.
   • He was hospitalized from August 10 to September 2, 1961, and retired on November 6, 1961. He continued receiving medical treatment until November 29, 1961.

3. Claim for Compensation:

   • Villanueva filed a claim for compensation, alleging that his illness was work-related. He spent P512.00 on medical treatment.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Presumption of Compensability: Under Section 44 of Act 3428, there is a presumption that a workman's claim is compensable. The burden is on the employer to prove that the illness was not caused or aggravated by the nature of the work.
2. Work Conditions and Illness: The Court found that Villanueva's work conditions, including exposure to dust, hot air, and night shifts, weakened his body's resistance and facilitated the activation of dormant tuberculosis.
3. Delay in Filing: The delay in filing the claim is not a jurisdictional defect unless the employer can show prejudice. The Court emphasized the need to protect workers, who are often at a disadvantage compared to employers.
4. Protection of Workers: The Court highlighted the principle under Article 24 of the Civil Code, which mandates vigilance in protecting parties at a disadvantage in contractual or property relations.