G.R. No. L-32982 November 5, 1991
CONRADO A. ZARAGOSA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, CALTEX (PHIL.) INC., and THE LIVERPOOL and LONDON & GLOBE INSURANCE CO., LTD. represented by WISE & CO., INC., General Agents, respondents.

FACTS

Petitioner Conrado Zaragosa was employed as a laboratory tester by Caltex (Phil.) Inc. from 1954 to 1965. In September 1965, the company physician diagnosed him with allergic or contact dermatitis, finding him reactive to cracked naptha and benzene, hydrocarbons he handled in his work. The doctor recommended avoiding direct contact. Caltex denied Zaragosa’s request for a transfer to another department. Consequently, he accepted an offer for termination due to redundancy, receiving separation pay. After his resignation, he sought other employment unsuccessfully, citing his age and lack of training in other fields.
Zaragosa filed a claim for compensation. The Acting Referee awarded him only P178.33, representing 60% of his average weekly wage for the period from October 15 to November 2, 1965, when he was on sick leave prior to his resignation. The Workmen’s Compensation Commission affirmed this limited award, ruling his disability was merely temporary and total only for that specific period, and that his subsequent unemployment was due to his voluntary resignation and redundancy, not his illness.

ISSUE

Whether the Workmen’s Compensation Commission erred in limiting Zaragosa’s disability benefits to a short period of temporary total disability, disregarding his subsequent inability to secure gainful employment after resignation due to his work-related illness.

RULING

Yes. The Supreme Court reversed the Commission’s decision. The legal logic centers on the interpretation of “total disability” under Section 14 of the Workmen’s Compensation Act. The Court held that total disability contemplates the incapacity to earn wages in the same kind of work or a similar job for which the employee is trained. Zaragosa’s work-related dermatitis permanently incapacitated him from returning to his former occupation or any work involving contact with the causative chemicals. His request for transfer was denied, forcing his resignation.
The Court emphasized that his ensuing continued unemployment was a direct consequence of his ailment, not merely his voluntary resignation. Where an employee is forced to retire early due to a persisting work-connected illness and remains unemployed despite efforts to find work, this condition constitutes total disability entitling him to maximum benefits. The Workmen’s Compensation Act, as a social legislation, must be construed liberally in favor of labor. Therefore, Zaragosa was awarded the maximum compensation of P6,000.00 for temporary total disability.