G.R. No. L-18737; November 29, 1962
FLORENCIO REBODOS, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and BENGUET CONSOLIDATED, INC., respondents.

FACTS

Florencio Rebodos was employed by Benguet Consolidated, Inc. from September 1, 1948, working as a mucker, miner, and later as a miner capataz. On April 17, 1958, he was separated from service after contracting pulmonary tuberculosis. He filed a compensation claim, and the hearing officer awarded him benefits. The respondent company appealed to the Workmen’s Compensation Commission.
Medical records showed Rebodos had a pre-employment examination where he was found fit. An X-ray in November 1950 revealed fibroid pulmonary tuberculosis, probably non-active, and he was allowed to continue working. Subsequent examinations through early 1956 indicated the condition remained stationary or inactive. However, X-rays in 1957 showed new lesions. He was hospitalized from June 1956 to January 1958 and was eventually discharged with a diagnosis of minimal, chronic, and inactive bilateral pulmonary tuberculosis.

ISSUE

The core issue is whether Rebodos’s illness, tuberculosis, which was contracted during employment, was aggravated by the nature of his work, thereby entitling him to compensation benefits under the Workmen’s Compensation Act.

RULING

The Supreme Court affirmed the decision of the Workmen’s Compensation Commission, which absolved the employer from liability. The Court upheld the Commission’s factual finding that no causal relationship existed between the claimant’s employment and the aggravation of his illness. The legal logic rests on the principle that factual findings of the Commission, when supported by substantial evidence, are conclusive and not subject to review.
The Commission’s analysis was pivotal: Rebodos’s tuberculosis did not worsen during his more strenuous periods as a mucker and miner but progressed when he held the less strenuous supervisory role of capataz. This reversal of the expected progression led the Commission to conclude that the aggravation was due to extraneous factors. Specifically, the Commission found substantial evidence that Rebodos’s gambling habits, causing late nights and lack of sleep, greatly contributed to the development and progress of his illness. Since the aggravation was attributable to the claimant’s personal dissipation and not to his employment conditions, the employer was not liable for compensation.
The Court also rejected procedural objections. It ruled that the company’s petition for review before the Commission was timely filed within granted extensions. Furthermore, the petitioner’s failure to raise the issue of the employer’s alleged non-controversion of the claim at the lower levels precluded its consideration on appeal. Therefore, the decision denying compensation was affirmed.