G.R. No. L-43687. September 22, 1977
ERENEO DE LA CRUZ, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC HIGHWAYS), respondents.

FACTS

Ereneo de la Cruz entered government service in 1934 at age 24, working as a “caminero” for the Bureau of Public Highways in Aklan. His duties involved road repair, requiring constant outdoor work under the sun, exposure to dust, dirt from vehicles, and rain. He continued in this employment until his retirement on June 30, 1973, at age 63.
In January 1973, while working, de la Cruz and other camineros were drenched by rain. He subsequently developed a fever and cough. He received outpatient treatment at Aklan Provincial Hospital from January to May 1973 and was diagnosed by a private physician with “Pulmonary Tuberculosis, Far Advanced.” An X-ray revealed half of his lung area was irreparably damaged. Due to this condition, he could no longer work and was confined to his home until retirement. He incurred medical expenses totaling P554.95.

ISSUE

Whether the Workmen’s Compensation Commission erred in reversing the Acting Referee’s award of compensation benefits to de la Cruz for his tuberculosis.

RULING

The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award. The legal logic is anchored on the presumption of compensability under the Workmen’s Compensation Act. The Court found that de la Cruz contracted tuberculosis in the course of his employment, as the nature of his work as a caminero—involving prolonged exposure to the elements, dust, and physical strain—directly caused or at least aggravated his illness. This satisfies Section 2 of the Act, which requires only that the illness be directly caused by or aggravated by the nature of the employment.
The Court further held that the claim was not barred by de la Cruz’s retirement. Compensation under the Act is a statutory liability that prescribes in ten years, and there was no showing the employer was prejudiced by any delay in filing. Critically, the respondent employer (Bureau of Public Highways) failed to seasonably controvert the claim, resulting in a waiver of all non-jurisdictional defenses, including any challenge to the work-connection of the illness. Consequently, the employer was ordered to pay total disability compensation (P4,992.00), medical expenses (P554.95), attorney’s fees, and administrative costs, and to provide necessary medical services for the claimant’s recovery.