G.R. No. 8448 - People vs Alegado

The petitioner, Demetrio D. Molet, is the administrative officer of the Provincial Health Office in Virac, Catanduanes.
On January 15, 1975, he filed a petition with the Workmen’s Compensation Unit in Naga City, seeking compensation benefits for episodes of hypertension.
His claim is based on his alleged experiences of attacks occurring in 1953, 1963, 1968, 1969, 1972, 1973, and on December 7, 1974, with the notice stating that he suffered temporary disability each time.

Attached to his filing was a Notice of Injury or Sickness and Claim for Compensation dated December 23, 1974.
The claim mentioned repeated temporary disabilities, though it did not specify the duration of each episode.

The Provincial Health Officer of Virac, Catanduanes, submitted an employer’s report dated December 20, 1974.
The report acknowledged that the petitioner’s sickness was contracted “while in discharge of his duties” and did not contravene the employee’s right to compensation.

A physician’s report from the Eastern Bicol Medical Center provided a detailed commentary on the petitioner’s illness, noting that his office work aggravated the recurrence of hypertension.
The report additionally mentioned his predisposition to pulmonary infections due to the nature of his service.
A separate medical evaluation submitted by the Compensation Rating Medical Officer of Regional Office No. 6 confirmed findings including high blood pressure readings (160/90 and 200/120), X-ray findings indicating Koch’s focus in the right apex, and stated a diagnosis of temporary total disability for one year (B-occurrence) and a temporary partial disability rated at 34%.

The petitioner also produced medical certificates issued on December 12, 1974, by the Eastern Bicol Medical Center.
Approved sick leaves from 1963 and 1969 were submitted, corroborating his admission of recurrent hypertension.

The Acting Referee of the Compensation Task Force dismissed the petitioner’s claim on the grounds that there was no demonstration of any actual physical disability.
The Referee’s order noted that despite the recurrent attacks, the petitioner consistently returned to work, and thus, there was no impairment of his earning capacity or sustained physical disability as required under the law.
Subsequent to the dismissal, the petitioner filed an appeal addressed to the President of the Philippines, although copies were also furnished to the Solicitor General, the Secretary of Labor, and the Acting Referee at Regional Office No. V.

The Workmen’s Compensation Commission reviewed the case, focusing on whether the appeal was properly filed, despite being directed to what was considered the wrong forum.
The Commission noted that the appeal had been filed after the Referee’s order had become final and executory, which raised issues concerning the proper venue for the filing.
Despite the technical filing irregularity, the Commission approached the merits of the claim, recognizing that the petitioner’s claim was substantively supported by the evidence and the employer’s admittance that the illness was work-related.

Whether the appeal, although filed with the wrong forum (addressed to the President), should be given due course for review even after the Referee’s order had become final and executory.
Whether the petitioner’s claim for compensation is meritorious given that his recurrent episodes of hypertension, as proven by medical evidence and corroborated by the employer’s report, constitute a work-related illness under the Workmen’s Compensation Act.
Whether technical deficiencies in the filing process should bar the petition, considering the underlying substantial justice of the case.