G.R. No. L-42737 December 29, 1978
EDUARDO HERNANDEZ, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and CENTRAL TEXTILE MILLS, INC., respondents.

FACTS

Petitioner Eduardo Hernandez, employed as a machine operator by respondent Central Textile Mills, Inc., filed a claim for disability benefits under the Workmen’s Compensation Act. He alleged that he contracted Pulmonary Tuberculosis (PTB), minimal, which was either caused or aggravated by his employment, leading to a six-month disability period starting October 23, 1974. His attending physician, Dr. Aida Villanueva, submitted a report supporting this diagnosis and recommending rest. The Hearing Officer awarded compensation, a decision affirmed by the Regional Office.
The respondent employer contested the claim, arguing the illness was not work-connected and presenting affidavits stating Hernandez performed light work in a sanitary environment. The Workmen’s Compensation Commission reversed the award, dismissing the claim. The Commission relied on earlier x-ray reports from October 1974 and August 1975, which it interpreted as showing inactive or negative findings, to conclude the petitioner was not disabled during the claimed period and that the physician’s diagnosis lacked supporting x-ray evidence.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing the claim by disregarding the attending physician’s report and misinterpreting the medical evidence.

RULING

The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic centers on the established evidentiary rules in workmen’s compensation cases. The Court held that the physician’s report of sickness is by itself sufficient evidence to support a compensation claim and that x-ray reports are not indispensable. The Commission erred in requiring such x-ray confirmation. Furthermore, the Commission misinterpreted the x-ray evidence it relied upon. The October 1974 report, stating “PTB, Minimal fibro-calcific, Inactive,” actually confirmed the presence of the disease, not its absence. The notation “Fit to resume work” pertained to his condition at that specific time, but it did not negate the subsequent disability certified by Dr. Villanueva beginning October 23, 1974. The August 1975 report was irrelevant as it fell outside the claimed disability period, during which petitioner had already resumed work. Therefore, the Commission’s findings were not supported by substantial evidence. The presumption of compensability under the Act, coupled with the unrebutted physician’s report, warranted the grant of benefits. The Court ordered the respondent company to pay the disability compensation, attorney’s fees, and administrative costs.