Title
Laguna Tayabas Bus Co. vs. Consunto
Case
G.R. No. L-12726
Decision Date
May 20, 1960
Gerardo Estiva, a bus inspector, died of cerebral hemorrhage. His widow claimed it resulted from a work-related head injury. The Workmen’s Compensation Commission ruled in her favor, supported by evidence of trauma and the principle of resolving doubts in favor of workers. Compensation was awarded.

Case Summary (G.R. No. L-12726)

Relevant Facts

Gerardo Estiva was employed until November 24, 1954, earning a daily wage of P7.04. On November 24, 1954, he died from cerebral hemorrhage at the hospital, but the claim for death benefits under the Workmen's Compensation Act was initially dismissed by Referee Ricardo S. Inton on June 1, 1956. The controversy primarily centers on whether Estiva sustained a traumatic injury leading to his condition while performing his duties.

Evidence Presented by the Claimant

The claimant argued that Estiva bumped his head while on the bus on November 23, 1954, which led to the hemorrhage. Supporting this claim, Dr. Villarasa testified that he observed a slight swelling on Estiva's head after he was brought to his clinic. Other witnesses testified to Estiva's complaints of severe headache and observed signs of distress while on the bus. However, cross-examination raised doubts about the veracity of these accounts regarding the injury.

Evidence Presented by the Respondent

The bus company countered the assertions by presenting evidence suggesting that there was no accident causing Estiva’s injury. Dr. Serafin Pangat examined Estiva at the hospital and noted the absence of any traumatic evidence that could have resulted from an external injury. He attributed the hemorrhage to hypertension, citing that any minor trauma would have been detectable shortly after the alleged incident, which he found not to be the case.

Workmen's Compensation Commission's Decision

The WCC ultimately reversed the referee's initial decision, concluding that there was enough evidence to support the claim of injury while performing work duties. The WCC opined that the evidence presented by the claimant outweighed the respondent's assertions, especially highlighting Dr. Villarasa's observations and the possibility that the delay in treatment may have influenced subsequent examinations.

Legal Findings and Applicable Law

The case referenced the provisions of Act No. 3428 regarding workers’ compensation. Section 46 states that the decisions of the WCC are appealable, and according to Section 2 of Rule 44, only questions of law may be raised on appeal, indicating a robust deference to findings of fact made by the WCC. The Supreme Court noted that the preponderance of evidence and th

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