Case Summary (G.R. No. L-20202)
Employment Background
Ciriaco Hernandez was employed by the Manila Electric Company (MERALCO) as an automotive mechanic since May 15, 1930. His duties involved the dismantling, repair, and installation of various truck components. At the time of his employment, he was reported to be in good health.
Medical Conditions and Retirement
On January 15, 1953, Hernandez was diagnosed with pulmonary tuberculosis after 23 years of service. From 1953 to 1959, his X-ray examinations consistently indicated signs of tuberculosis, prompting treatment from MERALCO's medical staff. Additionally, he suffered from an inguinal hernia, for which he underwent surgery in 1954, and carcinoma of the prostate, which required surgery in September 1959.
Following MERALCO's policy on retirement, Hernandez was notified on May 8, 1959, that he would be retired on December 31, 1959. However, due to his deteriorating health and at his own request, he retired earlier on November 25, 1959 and received his retirement benefits.
Claim for Compensation
On March 10, 1960, Hernandez filed a notice of sickness and a claim for compensation, later amended on March 7, 1961, asserting that his illness forced him to retire, but MERALCO failed to provide compensation as mandated by law. Following the submission of MERALCO's answer contesting the claim, a hearing was held by the Department of Labor.
Initial Ruling and Appeal
On February 1, 1962, the hearing officer ruled in favor of Hernandez, granting him P4,000 as temporary total disability compensation. MERALCO appealed this decision to the Workmen's Compensation Commission, which reversed the hearing officer’s ruling on June 25, 1962. A motion for reconsideration by Hernandez was denied by the Commission on August 22, 1962, prompting his appeal to a higher authority.
Court Analysis and Findings
The Supreme Court found that Hernandez's decision to retire ahead of schedule was primarily due to his illness rather than age. Given that his pulmonary tuberculosis continued to be a concern until 1961, the Court concluded that the illness directly impacted his employment capability. The Workmen's Compensation Commission's rejection of compensation on the grounds that 23 years had elapsed before the disease manifested was deemed insufficient. The Court reaffirmed that once a disease is established as arising from employment, it is presumed to be work-related unless substantial evidence indicates otherwise.
Final Determination of Compensation
The ruling established that Hernandez was entitled to compensation payments solely for the period he was unable to work before his retirement, emphas
...continue readingCase Syllabus (G.R. No. L-20202)
Case Overview
- This case involves a petition for review of a decision made by the Workmen's Compensation Commission regarding the entitlement of Ciriaco Hernandez, a retired employee of the Manila Electric Company (MERALCO), to disability compensation due to illnesses contracted during his employment.
- The main issues include the nature of Hernandez's illnesses, the implications of his retirement, and the legality of the compensation claims made by him.
Factual Background
- Ciriaco Hernandez was employed by MERALCO as an automotive mechanic starting May 15, 1930.
- His work involved dismantling, repairing, and installing vehicle components, and he was in good health until January 15, 1953, when he was diagnosed with pulmonary tuberculosis after 23 years of service.
- Between 1953 and 1959, Hernandez underwent treatment for his tuberculosis and also suffered from an inguinal hernia, for which he was operated on in 1954, and later, carcinoma of the prostate, for which he was operated on in September 1959.
- On May 8, 1959, MERALCO notified Hernandez of his compulsory retirement on December 31, 1959, based on the company's policy regarding employees who reach 60 years of age or complete 30 years of service. Hernandez chose to retire early on November 25, 1959, and received his retirement benefits.
Legal Proceedings
- On March 10, 1960, Hernandez filed a notice of sickness and a claim for compensation with the Department of Labor, which was later amend