GR L 26173; (October, 1969) (Digest)
G.R. No. L-26173 October 31, 1969
OPERATORS, INCORPORATED, petitioner, vs. RICARDO CACATIAN and WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
Claimant Ricardo Cacatian was employed by the American Biscuit Company, Inc. (petitioner Operators, Incorporated). On May 7, 1954, while in the line of duty, he suddenly lost consciousness, fell, and hit his head on the cement floor. He was taken to San Juan de Dios Hospital and later to the National Mental Hospital, where he was found to be suffering from epilepsy. The claimant had no family history of epilepsy and was not afflicted with the disease prior to the accident. The employer contested the claim, arguing the epilepsy was an idiopathic disease caused by the claimant’s personal circumstances (evening classes, exam preparations, and a quarrel with his sweetheart) and not by his employment. The Workmen’s Compensation Commission found the injury from the fall caused the epilepsy and awarded compensation. The employer appealed, asserting the Commission erred in not finding the condition idiopathic and in not dismissing the claim for being filed seven years late.
ISSUE
1. Whether the claimant’s epilepsy is compensable under the Workmen’s Compensation Act or if it was an idiopathic condition unrelated to employment.
2. Whether the delay of seven years in filing the claim bars recovery.
RULING
1. The epilepsy is compensable. The Court affirmed the Commission’s finding that the fall at work, which caused the claimant’s head to hit the cement floor, resulted in his epileptic condition. The statutory presumption under the Workmen’s Compensation Act that a claim is compensable in the absence of substantial contrary evidence applies. The employer failed to present substantial evidence to overcome this presumption or to successfully prove the condition was idiopathic and caused solely by personal factors. The Court cited analogous American jurisprudence (Chicago Park District and Rialto Mining Co.) holding that epilepsy resulting from or aggravated by a work-related injury is compensable.
2. No, the delay does not bar recovery. The failure to file a claim within the statutory period does not affect the jurisdiction of the Workmen’s Compensation Commission. This doctrine, established in prior cases, was reaffirmed.
The decision of the Workmen’s Compensation Commission was affirmed. Costs against the petitioner.