Title
Manila Railroad Co. vs. Workmen's Compensation Commission
Case
G.R. No. L-21902
Decision Date
Aug 10, 1967
The Supreme Court ruled in favor of a trackman with pulmonary tuberculosis, affirming the Workmen's Compensation Commission's decision due to the employer's failure to contest the disability claim within the required timeframe.
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Case Digest (G.R. No. L-21902)

Facts:

  • The case involves the Manila Railroad Company (petitioner) and the Workmen's Compensation Commission along with Ricardo Balmeo (respondents).
  • Ricardo Balmeo began working as a temporary trackman on July 1, 1958, after passing a pre-employment physical examination.
  • He was appointed as a permanent trackman on August 16, 1960, with an annual salary of P1,500.
  • His job involved physically demanding tasks, including lifting iron rails and working in harsh weather conditions.
  • On January 11, 1961, Balmeo was diagnosed with pulmonary tuberculosis after an X-ray examination.
  • Despite his illness, he continued working until his dismissal on June 16, 1961.
  • Balmeo filed a claim for disability compensation on October 10, 1961, after being dismissed.
  • The Manila Railroad Company contested the claim, submitting an employer's report on November 10, 1961.
  • A hearing officer ruled in favor of Balmeo, awarding him compensation benefits.
  • The Manila Railroad Company appealed to the Workmen's Compensation Commission, which affirmed the hearing officer's decision on July 15, 1963.
  • The company's motion for reconsideration was denied on August 23, 1963.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed the Manila Railroad Company's petition for review.
  • The Court affirmed the decision of the Workmen's Compensation Commission, confirming its jurisdiction over Balmeo's claim.
  • ...(Unlock)

Ratio:

  • The Court emphasized that failure to comply with notice and filing requirements under Section 24 of Act 3428 does not create a jurisdictional defect.
  • If the employer is aware of the employee's illness or injury, the lack of timely notice does not prevent the claim for compensation....continue reading

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