G.R. No. L-20202 - Herdez vs. Workmen's Compensation Commission

Ciriaco Hernandez was employed by Manila Electric Company (MERALCO) as an automotive mechanic starting May 15, 1930.
His work involved dismantling, repairing, and installing transmissions, differentials, and steering wheels for trucks.
At the time of his employment, Hernandez was in good health.

On January 15, 1953, after 23 years of continuous service, Hernandez was diagnosed with pulmonary tuberculosis.
From 1953 to 1959, his periodic X-ray examinations indicated a "minimal, fibrotic infiltration of both apices."
During the period of illness, he received treatment from MERALCO’s in-house physician at the company clinic.
Hernandez also suffered from inguinal hernia and underwent an operation in 1954.
Later, on September 18, 1959, he was diagnosed with carcinoma of the prostate and was operated on accordingly.

Employees who completed 30 years of continuous, faithful and satisfactory service or reached their 60th birthday were to be retired from service.
Hernandez was advised on May 8, 1959, that he would be retired on December 31, 1959 and paid his "Retirement Account."

At his own request, Hernandez was retired on November 25, 1959 and received his retirement benefits, even though he was 69 years old.
On March 10, 1960, he filed a Notice of Sickness and Claim for Compensation with the Department of Labor, later amended on March 7, 1961.
Hernandez claimed that his premature retirement was due to disability from illnesses suffered in the course of employment, and that MERALCO violated statutory compensation provisions.

After MERALCO filed its answer, the Department of Labor, Regional Office No. 4, held a hearing.
On February 1, 1962, the hearing officer decided in favor of Hernandez, awarding him temporary total disability compensation amounting to P4,000.00 (with additional fees and limits for attorney’s charges).
MERALCO filed a petition for review of the hearing officer’s decision before the Workmen’s Compensation Commission.
On June 25, 1962, the Associate Commissioner reversed the hearing officer’s decision.
Upon a motion for reconsideration by Hernandez, the en banc Workmen’s Compensation Commission affirmed the reversal by resolution on August 22, 1962.
Hernandez subsequently appealed the decision.

Hernandez’s retirement was compelled by his weakened physical condition due to his pulmonary tuberculosis, rather than purely his age.
At the time of retirement (November 25, 1959), his pulmonary tuberculosis was actively being treated and was only pronounced arrested on April 6, 1961.
The Employer’s Report of Sickness indicated his retirement was due to “minimal PTB, bilateral, fibroid.”
MERALCO argued that the 23-year lapse before the manifestation of tuberculosis indicated that the disease could not have been due to working conditions.

Whether Hernandez’s pulmonary tuberculosis, which manifested after 23 years of employment, was causally related to his employment conditions.
Evaluation of the employer’s argument that the long latent period ruled out a causal connection with his work environment.

Whether Hernandez’s claim for disability compensation is valid given the filing timeline and the fact that his retirement benefits were already paid.
Determining the correct period for compensation, particularly regarding the 36 days from his early retirement on November 25, 1959, to his scheduled compulsory retirement on December 31, 1959.
Whether the prescription or deadline for filing the claim was met, considering that his formal Notice of Sickness was filed beyond the two-month period.

Whether compensation for disabilities should extend beyond December 31, 1959, especially after retirement benefits were disbursed.
The differentiation between compensation payments (tied to loss of earning capacity) and medical/hospital service obligations under the Workmen’s Compensation Act.