Facts:

The case involves the Pangasinan Transportation Company, Inc. as the petitioner and the Workmen's Compensation Commission along with Cecilio Gatdula as the respondents. The events leading to the case began when Cecilio Gatdula, a driver for the Pangasinan Transportation Company, was employed from January 1950. His work involved driving on rough and dusty routes in Pangasinan, which included Dagupan-Tayug, San Jose-Dagupan, and Dagupan-Mangatarem. His daily schedule required him to work from 6:00 AM to 6:00 PM, alternating with a later shift until 8:00 PM. On June 20, 1953, while performing his duties, Gatdula was involved in an accident that resulted in injuries, for which he was hospitalized until August 22, 1953. The company compensated him for these injuries, and he returned to work on January 17, 1954.

However, by the end of 1954, Gatdula began experiencing persistent chest and back pains, along with headaches. Despite receiving temporary relief from first aid trea...

Facts:

1. Employment Details:

   • Cecilio Gatdula was employed as a driver by Pangasinan Transportation Company, Inc. starting January 1950.
   • His assigned routes were rough and dusty, and he often assisted in loading and unloading baggage.
   • His work schedule was demanding, with shifts lasting from 6:00 AM to 6:00 PM and 6:00 PM to 8:00 PM on alternate days.

2. Accident and Initial Illness:

   • On June 20, 1953, Gatdula met with an accident while driving, resulting in injuries. He was hospitalized until August 22, 1953.
   • The company compensated him for his injuries, and he returned to work on January 17, 1954.

3. Development of Tuberculosis:

   • By the end of 1954, Gatdula complained of chest and back pains, as well as headaches.
   • On January 23, 1955, he was diagnosed with acute bronchitis and was ordered to stop working.
   • A month later, he was found to have moderate pulmonary tuberculosis, which later became chronic and bilateral.

4. Filing of Claim:

   • Gatdula filed a notice of sickness and claim for compensation on September 2, 1957, more than two years after his illness was discovered.
   • The company argued that the claim was barred due to the delay in filing and contested the compensability of the illness.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Timeliness of Claims:

   • The Court emphasized that Section 24 of the Workmen’s Compensation Act requires both notice of injury and a claim for compensation to be filed within specific timeframes. While notice of injury can be excused if the employer has actual knowledge, the claim for compensation must still be filed within two months unless the employer has voluntarily made compensation payments.

2. Jurisdiction of Hearing Officers:

   • The Court reaffirmed that regional offices have jurisdiction over Workmen’s Compensation cases under Reorganization Plan No. 20-A, as this does not conflict with the Workmen’s Compensation Act.

3. Presumption of Compensability:

   • The Court initially applied the presumption of compensability under the Workmen’s Compensation Act, which holds that an illness or injury arising in the course of employment is presumed compensable unless the employer proves otherwise. However, this presumption was rendered moot by the untimely filing of the claim.

4. Distinction Between Notice and Claim:

   • The Court clarified that notice of injury and a claim for compensation are distinct requirements under the law. Section 27 of the Act, which excuses delays in notice, does not apply to delays in filing claims.

5. Final Decision:

   • The Court ultimately reversed its initial decision and dismissed Gatdula’s claim, holding that the failure to file the claim within the statutory period was fatal to the case.