Case Digest (G.R. No. L-19843)
Facts:
National Power Corporation v. Workmen's Compensation Commission, G.R. No. L-19843, January 30, 1965, the Supreme Court En Banc, Bautista Angelo, J., writing for the Court.Enrique Gulmatico was employed by National Power Corporation as an assistant stockman at P140 per month. His duties included checking materials and supplies, opening boxes, issuing spare parts, arranging equipment in the warehouse, acting as stockkeeper, attending errands within the plant compound, and rendering overtime on emergency repairs to keep operations running. He frequently missed meals and stayed late to close the warehouse.
On November 4, 1956 (a Sunday), Gulmatico worked overtime at the request of his shift supervisor and manually pumped gasoline into vehicles during a plant power shutdown. He experienced stomach pain during the day but continued working; by the evening he had severe stomach pain and non‑projectile vomiting. Plant physician Dr. Echeverri gave temporary treatment, and Gulmatico was later transferred to Avellanosa Hospital for an operation that could not be performed due to a sudden blood pressure drop; he lost consciousness and died. The physician certified the cause as “ruptured chronic perforating gastric ulcer on lesser curvature of the stomach, acute generalized peritonitis, toxemia.”
Gulmatico’s widow, Dominica Luna, filed a claim for compensation with the Uigan City branch of the Department of Labor. Hearing officer Luis B. Buendia awarded the claimants P4,000.00 as compensation and P200.00 for burial expenses. National Power Corporation appealed to the Workmen’s Compensation Commission (WCC), which, through Chairman Nieves Baens del Rosario, affirmed the award on November 6, 1961 and added the reglementary review fees under Section 55 of the Act. The employer then brought a petition for review to the Supreme Court.
The principal defense raised by the employer was that the claim was barred by prescription: under Section 21 of the Workmen’s Compensation Act a claim for death must be filed within three months (unless the employer voluntarily made compensation payments), and here the death occurred November 5, 1956 while the claim was filed December 2, 1958. The Commission, however, found that the employer had knowledge of the deat...(Subscriber-Only)
Issues:
- Did the Workmen’s Compensation Commission acquire jurisdiction despite the claimant’s filing more than three months after the employee’s death, or was the claim barred by prescription?
- Was the deceased’s death (ruptured gastric ulcer with acute peritonitis) compensable as a condition contracted or aggravated in ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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