G.R. No. L-19863 - National Development Co. vs. Workmen's Compensation Commission

The respondent, Luz Aguirre, began employment at the respondent company on February 18, 1946, initially as an apprentice in the Weaving Textile Mills.
She was promoted to Battery Hand on April 9, 1946, then to Spare Weaver on March 26, 1947, and finally to Regular Weaver on March 5, 1951, a post she held until her separation on June 30, 1953.

As a spare weaver, Aguirre’s duties included operating looms, connecting broken threads, rolling finished cloths, and lifting approximately 40-kilo rolls of cloth when they obstructed her work area.
Her job required frequent manual handling and repetitive tasks, such as stopping or starting each of the 12 assigned looms by pushing corresponding handles a minimum of 15 times per hour, considering machine stoppages due to thread breakage, entanglements, or overheating.
She was regularly assigned to the strenuous second (2:00 p.m. to 10:00 p.m.) and third shifts (10:00 p.m. to 6:00 a.m.), which heightened the taxing nature of her work.

During the latter part of April 1953, while lifting a roll of cloth, Aguirre experienced chest pains and subsequently spat blood.
She sought medical attention from the respondent company’s Medical Department, having reported the incident to her Overseer, Jose Soriano.
Although initially given light work after a few days’ rest, she was eventually laid off from service due to her sickness.

Clinical records show that symptoms of pulmonary tuberculosis (PTB) such as chest and back pains, occasional coughs, and weight loss were evident as early as June 1950.
The respondent’s medical department had noted a “suspicious density” in the 1st rib and 1st intercostal space indicative of Koch infection.
An X-ray on February 19, 1953, at the Quezon Institute revealed:

In the right lung: a calcified focus at the apex, fibrosis at the second interspace, and an enlarged, dense hilar shadow, indicative of a healed lesion.
In the left lung: an exudative lesion at the second interspace, considered acute and active pulmonary tuberculosis.

Treatment records further disclose that Dr. Lorenzo Yuson treated her from December 1952 to November 1958, incurring medical expenses amounting to P900.00.

On June 6, 1960, Aguirre filed a compensation claim attributing her pulmonary tuberculosis to her employment with the respondent.
The Hearing Officer, after conducting proceedings, awarded her compensation benefits comprising:

The Workmen’s Compensation Commission (WCC) affirmed this award, basing its decision on the assessment that Aguirre’s work conditions were both taxing and physically demanding.

The National Development Company, being a government-owned and controlled corporation, failed to notify or report the employee’s condition within the time frame prescribed by Section 45, paragraph 2 of the Workmen’s Compensation Law.
This failure was interpreted as a renunciation of the right to controvert the claim, as it barred the employer from presenting any defense or contesting the claim based on the employee’s alleged tardiness in filing the claim.

The petitioner contended that the Commission exceeded its jurisdiction or abused its discretion in awarding attorney’s fees by:

Arguing that the petitioner had no role in the respondent’s hiring of counsel.
Challenging the basis for awarding fees under Section 47 of Act 3428 (as amended) vis-à-vis Section 31.
Positing that Article 2208 of the Civil Code should apply if there was any deficiency in the Act.

The decision affirmed that the statutory scheme, including Section 31 and the relevant Civil Code provisions (Article 18 and Article 2208), supports the award of attorney’s fees against the employer in such cases.

Whether the employer’s failure to report the employee’s condition within the prescribed period, as mandated by Section 45 of the Workmen’s Compensation Law, constituted a renunciation of its right to controvert the claim.
Whether the Workmen’s Compensation Commission correctly exercised its authority in awarding attorney’s fees to the respondent, particularly in light of the provisions of Section 31 and Section 47 of the relevant statute, as well as the applicable Civil Code provisions.
Whether the admission of hearsay evidence by the Commission, as alleged by the petitioner, affected the integrity of the findings and the overall decision.