Case Summary (G.R. No. L-45906)

Factual Background of the Case

• Baldomero Aribon, a 39-year-old field worker, began his employment with Canlubang Sugar Estate in 1957.
• He worked daily from 7:00 AM to 4:00 PM, earning a daily wage of P4.50.
• In 1967, he experienced stomach pains and was diagnosed with a peptic ulcer at the company's hospital.
• Despite treatment, his condition recurred, leading him to stop working on November 15, 1967, and retire upon medical advice.

Initial Claim and Decision

• On March 10, 1975, Aribon filed a claim for disability benefits under the Workmen's Compensation Act, asserting his illness was work-related.
• Acting Referee Esguerra ruled in favor of Aribon, awarding him P6,000 in compensation based on his average weekly wage and the duration of his disability.

Appeal by Respondent

• The respondent company appealed the decision, arguing that the claim should be dismissed due to a lack of medical evidence, specifically the absence of a GI series test to confirm the peptic ulcer diagnosis.
• The Workmen's Compensation Commission reversed the initial ruling, citing the lack of supporting medical evidence.

Petition for Review

• Aribon filed a petition for review, contending that he had not received proper notice of the Commission's decision, which the respondent claimed had become final.
• The respondent argued that the absence of the GI series test constituted a failure to substantiate the claim and that the initial award was excessive.

Examination of Notice and Due Process

• The Court found insufficient evidence that proper notice of the Commission's decision was served to Aribon or his counsel.
• The respondent's evidence, including registry return receipts, did not conclusively prove that notices were sent or received.
• The Court emphasized the importance of proper notice as a fundamental aspect of due process.

Legal Principles on Notice

• The Court reiterated that proper notice is essential for the administration of justice and that parties must be informed of actions affecting their rights.
• Citing previous cases, the Court noted that a lack of proper notice prevents a decision from becoming final.

Context of the Workmen's Compensation Commission

• The case was processed during a transitional period for the Workmen's Compensation Commission, which was experiencing a backlog and confusion regarding procedural requirements.
• Despite potential delays in the appeal process, the Court chose to exercise its equity jurisdiction in favor of Aribon, who was in a vulnerable financial position.

Entitlement to Disability Benefits

• The Court ruled that Aribon was entitled to disability benefits under the old Workmen's Compensation Act, as his claim was timely filed.
• The Court recognized the legal presumption that an illness arising during employment is work-related unless disproven by the employer.

Rejection of Medical Evidence Requirement

• The Court found that the absence of a GI series test did not invalidate Aribon's claim, as multiple doctors had diagnosed him with a peptic ulcer.
• The Court cited precedent allowing medical reports from attending physicians to serve as ...continue reading

Case Syllabus (G.R. No. L-45906)

Case Overview

• This case involves a petition to review the decision of the Workmen's Compensation Commission (WCC) that reversed a prior ruling by the Workmen’s Compensation Unit of Lucena City, which had awarded disability benefits to the petitioner, Baldomero Aribon.
• The decision was rendered by Justice Gutierrez, Jr. on November 7, 1985.

Factual Background

• Baldomero Aribon, a 39-year-old field worker for Canlubang Sugar Estate, had been employed since 1957, working from 7:00 AM to 4:00 PM, seven days a week, for a daily wage of P4.50 (approximately P32.62 weekly).
• In 1967, Aribon began experiencing stomach pains and consulted the company's hospital, where he was diagnosed with peptic ulcer. He continued working with medication but had to stop on November 15, 1967, on the recommendation of his doctor, Dr. Bunye.
• On March 10, 1975, Aribon filed a claim for disability benefits under the Workmen’s Compensation Act, asserting that his illness was work-related.

Initial Decision by Acting Referee

• The Acting Referee, Salvador C. Guevarra, ruled in favor of Aribon, awarding him P6,000 as compensation, calculated based on 60% of his average weekly wage for the duration of the disability.
• The award included additional fees for processing and attorney's fees for Aribon's counsel.

Appeal to the Workmen's Compensation Commission

• The respondent ...continue reading