Case Summary (G.R. No. 118552)
Facts of the Case
Pedro Villanueva began his employment with the Central Azucarera Don Pedro in 1933, starting as a "palero," later becoming a "fogonero," and finally a "cabo palero." Villanueva claimed to have suffered from various health issues, including fever, chest and back pains, and fatigue, leading to his cessation of work on July 28, 1961. Despite showing no significant health problems during routine examinations until then, X-rays later revealed he had minimal pulmonary tuberculosis.
Legal Basis and Presumption of Workmen’s Compensation
The petitioner contested the award of compensation primarily asserting that Villanueva's illness was unrelated to his work and that his claim was submitted beyond the legal timeframe stipulated in Section 24 of the Workmen's Compensation Act. However, according to the law, there is a presumption that a worker's claim is compensable, which requires the employer to prove that the employee's injury or illness was not caused or aggravated by the conditions of their work.
Evidence Presented
To counter the presumption in favor of Villanueva’s claim, the petitioner presented testimonies suggesting adequate working conditions and ventilation. However, this evidence was deemed insufficient to overcome the presumption established by the law. The Commission noted that working at night and performing laborious tasks contributed to the deterioration of Villanueva’s health, activating dormant tuberculosis in conjunction with the adverse conditions he faced.
Delay in Filing Claim
The petitioner also argued that the delay in filing the compensation claim should invalidate it. However, precedent cases have evolved, indicating that such delays are now viewed as non-jurisdictional defects unless the employer can show actual prejudice. This aligns with the principle found in Ar
...continue readingCase Syllabus (G.R. No. 118552)
Case Citation
- 133 Phil. 539
- G.R. No. L-24987
- Date of Decision: July 31, 1968
Overview of the Case
- The case involves a certiorari petition to review an award of compensation granted by the Workmen's Compensation Commission to the claimant, Pedro Villanueva.
- The decision appealed from is based on findings that are not substantially controverted by the petitioner.
Facts of the Case
- Employment History:
- Pedro Villanueva began working with Central Azucarera Don Pedro in 1933 as a "palero" after passing a pre-employment physical and medical examination.
- He was promoted to "fogónero" in 1939 and then to "cabo palero" in 1946, holding that position until July 28, 1961.
- Health Issues:
- Villanueva experienced fever, chest and back pains, body weakening, and coughing, which he claimed started as early as 1943.
- He reported spitting blood in 1959 while working.
- Medical examinations starting in 1952 indicated he was in good health until September 25, 1961, when he was diagnosed with minimal pulmonary tuberculosis.
- Medical Treatment:
- After hospitalization from August 10 to September 2, 1961, Villanueva retired on November 6, 1961, but continued to receive medical treatment until November 29, 1961.
- He incurred medical expenses amounting to P512.00 for treatment from Dr. Numeriano G. Presto.
Nature of Work and Work Conditions
- Villanueva's duties included:
- Cleaning the parrilla and scraping hardened ashes as a "palero."
- Supervising the dropping of bagasse as a "fogónero."
- Overseeing seven furnaces and maintaining wat