Case Digest (G.R. No. L-18434)
Facts:
The case involves petitioners Martina Lambino, acting on her own behalf and on behalf of her children Erlinda and Alejandra Mercado, against respondents N. Baens del Rosario, Chairman of the Workmen's Compensation Commission (WCC), and the City of Manila. The events leading to the case began with the employment of Juan Mercado, the deceased husband of Martina Lambino, who worked as a laborer for the City of Manila starting in 1919. His employment was interrupted by World War II but resumed in 1946. In April 1952, Juan Mercado fell ill and was diagnosed with advanced pulmonary tuberculosis. He died on May 7, 1953. The claim for death compensation was filed by Martina Lambino, asserting that her husband's illness was contracted or aggravated by his work conditions, particularly his exposure to the elements while performing his duties as a street cleaner and during the construction of the International Fair Grounds. The WCC dismissed the claim, stating that there was ins...
Case Digest (G.R. No. L-18434)
Facts:
The case involves a petition for review on certiorari by Martina Lambino, representing herself and her children, against N. Baens del Rosario (Chairman, Workmen's Compensation Commission) and the City of Manila. The petition seeks to review the decision of the Workmen's Compensation Commission (WCC), which dismissed the compensation claim for the death of her husband, Juan Mercado. Juan Mercado was a laborer employed by the City of Manila from 1919 until his death in 1953, with a brief interruption during World War II. In November 1952, he contracted rheumatism, which worsened due to his daily work as a sweeper, where he was exposed to heat and cold in the open air. In April 1952, he fell ill and was diagnosed with advanced pulmonary tuberculosis. Despite his illness, he was reinstated to work in November 1952 and assigned to the construction of the International Fair Grounds, where he was frequently overtaken by rain and exposed to the heat of the sun. He died on May 7, 1953, of tuberculosis. Martina Lambino filed a claim for death compensation, which was denied by the WCC for lack of evidence. Subsequent motions for reconsideration based on newly-discovered evidence were also denied by the WCC en banc.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
The Supreme Court based its decision on the premise that Juan Mercado's illness (pulmonary tuberculosis) was caused or aggravated by his work as a laborer (street cleaner or sweeper). The Court emphasized that the nature of his work, which involved constant exposure to dust, dirt, and the elements, was conducive to the development and aggravation of pulmonary tuberculosis. The Court also noted that the deceased's reinstatement to work in November 1952, despite his advanced tuberculosis, and his assignment to construction work where he was constantly exposed to rain and the heat of the sun, undoubtedly aggravated his ailment. Therefore, the Court concluded that the deceased's illness was compensable under Section 2 of Act No. 3428 (Workmen's Compensation Law). This holding aligns with the provisions of Act No. 3428, which compensates workers for illnesses caused or aggravated by the nature of their employment.