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

Case Overview

• This document pertains to a petition for review by Baldomero Aribon against the Workmen's Compensation Commission (WCC) and his employer, Canlubang Sugar Estate/C.J. Yulo & Sons, regarding a claim for disability benefits under the Workmen’s Compensation Act, which was dismissed by the WCC.

Factual Background

• Petitioner: Baldomero Aribon, a 39-year-old field worker employed since 1957.
• Employment Details:
  • Working hours: 7:00 AM to 4:00 PM, seven days a week.
  • Daily wage: PHP 4.50 (PHP 32.62 weekly).
• Health Issues:
  • Diagnosed with peptic ulcer in 1967 after experiencing stomach pains.
  • Continued working with treatment until retirement on November 15, 1967, as recommended by Dr. Bunye.
• Claim Filed: March 10, 1975, for disability benefits due to illness contracted from employment.

Initial Award by Acting Referee

• Decision: Granted disability benefits.
• Compensation: PHP 6,000.00 as maximum compensation benefits.
• Fees Ordered:
  • PHP 61.00 to the Workmen's Compensation Unit.
  • PHP 300.00 to petitioner’s counsel as attorney's fees.

Appeal and Reversal by WCC

• WCC Findings:
  • Claimed that Aribon was medically cleared ('OK na') and noted the absence of a GI Series test to substantiate the diagnosis of peptic ulcer.
  • Reversed the Acting Referee’s decision citing failure to meet requirements for the legal presumption of compensability.

Supreme Court Review

• Arguments from Respondents:

  • Decision was final due to lack of appeal from Aribon.
  • Insisted on the necessity of a GI series test to prove illness.
  • Argued that the maximum benefits awarded were excessive.

• Supreme Court Findings:

  • No clear proof of proper notice of the WCC’s decision to Aribon or his counsel.
  • The importance of due process in notice delivery was emphasized.
  • Acknowledged the confusion during the transition of the Workmen’s Compensation Commission’s functions.

Legal Principles

• Presumption of Compensability:

  • Illness that arises during employment is presumed to be work-related unless disproved by the employer.

• Requirement of Medical Evidence:

  • The absence of a GI series test was deemed insufficient to dismiss the claim given the clear medical diagnoses received from multiple doctors.

Key Legal Outcomes

• The Supreme Court ruled in favor of Aribon, reinstating the original award of PHP 6,000.00.
• The court highlighted that the conditions leading to Aribon's retirement due to his illness constituted total disability, qualifying him for maximum benefits under the Workmen’s Compensation Act.

Modifications

• Attorney's fees for the former counsel were disallowed.
• Administrative fees were directed to be paid to the Ministry of Labor and Employment.

Key Takeaways

• Due Process: Proper notice is essential for decisions to become final.
• Compensability Presumption: Illnesses occurring during employment carry a rebuttable presumption of work-relatedness.
• Medical Evidence: Formal tests like the GI series are not always necessary if clear clinical evidence supports the diagnosis.
• Disabi

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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 company appealed the decision,

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