Case Summary (G.R. No. 223845)
Background of the Case
Eustaquio Alejandro filed a compensation claim on January 15, 1973, asserting he sustained an injury—specifically, a vitreous hemorrhage in his left eye—due to an accident that occurred during work. The claim noted September 16, 1969, as the date of the accident, and he stopped working three days later. Alejandro retired from government service on September 20, 1969.
Notifications and Controversy
The respondent employer did not receive notice of the accident until Alejandro's claim was submitted in 1973. Although the employer filed a controversion asserting the injury did not arise from his employment, this was considered too late by the Acting Referee. A hearing was conducted, and, due to the respondent's absence, Alejandro's claims were received ex parte.
Initial Ruling by the Acting Referee
On January 6, 1975, the Acting Referee awarded Alejandro compensation amounting to P3,173.00 for lost wages under the Workmen's Compensation Act, alongside medical reimbursements of P500.00 for treatment related to the eye injury. This ruling relied heavily on evidence from Alejandro's attending physician, demonstrating that the injury was work-related.
Commission's Reversal and Grounds
The Workmen's Compensation Commission reversed this decision on December 18, 1975, stating there was insufficient evidence proving that Alejandro was disabled from the injury as he continued to work until his retirement, which was due to age, not injury-related disability. This reasoning was seen as a significant deviation from established jurisprudence that recognizes work-related injuries irrespective of immediate wage loss.
Effective Notification of Injury
Despite the employer's claims of being uninformed of the injury, the decision analyzes the employer’s knowledge—evidenced by the District Engineer's directive to Alejandro not to file for sick leave. This fact implies that the employer was aware of the injury when it occurred, thus binding them to the notification.
Merits of the Claim
The court found that Alejandro's injury arose from his employment, establishing a direct link between his work duties and the accident. Medical certifications supported his claims of enduring physical impairment and temporary disability due to the injury sustained while performing his job duties.
Wage Loss and Disability Claims
The Solicitor General contended that since Alejandro worked until his retirement, he did not incur wage loss, which typically affects benefits under Section 14. However, the court clarified that the ability to claim medical and permanent disability benefits did not depend on immediate wage loss but rather on the nature of the injury and its long-term impact, thus maintaining Alejandro's rights under Section 13 and Section 17 [applicable to total loss of the eye].
Conclusion
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Case Overview
- The case revolves around a petition for review on certiorari filed by Eustaquio Alejandro against the Workmen's Compensation Commission (WCC) and the Bureau of Public Highways in Catanduanes, following a decision that reversed an earlier award of compensation related to an injury he sustained at work.
- The case number is G.R. No. L-42595, decided on December 18, 1979, by the First Division of the Supreme Court of the Philippines.
Background of the Case
- Alejandro filed a compensation claim on January 15, 1973, citing an accident on September 16, 1969, where he suffered a "Truma -Vitreous Hemorrhage" in his left eye while supervising road asphalting.
- He notified his employer of the injury but did not specify when or to whom the notification was made.
- Alejandro retired from government service on September 20, 1969, just four days post-accident, having served approximately 28 years.
Employer's Response
- The employer received notice of the claim on January 15, 1973, and subsequently filed a report disputing the claim, asserting that they were not notified of the accident in a timely manner and that the injury did not arise during Alejandro's employment.
- The Solicitor General filed a notice of controversion, claiming the sickness was not work-related and did not result from employment conditions.
Hearing and Initial Decision
- The claim hearing was held on August 17, 1973, with the employer failing to appear. Consequently, Alejandro's evidence was accepted ex parte, leading to a decision by the Acting Referee on January 6, 1975.
- The Referee aw