G.R. No. L-17283; July 31, 1962
ILOILO DOCK & ENGINEERING CO., petitioner, vs. THE WORKMEN’S COMPENSATION COMMISSION and PABLO SANTIAGO, respondents.

FACTS

Pablo Santiago, an iron worker for Iloilo Dock & Engineering Co., suffered a slight compression fracture of the 12th thoracic vertebrae in a work-related accident on August 16, 1955. This injury incapacitated him for 14-6/7 weeks until November 30, 1955. The company physician certified he sustained a 20% permanent partial disability of the back. The petitioner company filed the required Employer’s Report of Accident, expressly stating it would not controvert Santiago’s right to compensation. Upon his return to work on December 1, 1955, Santiago performed his usual tasks and received the same wages as before the accident.
The Regional Administrator computed Santiago’s compensation, awarding amounts for medical services and temporary total disability under Sections 13 and 14 of the Workmen’s Compensation Act (WCA), which the company paid. However, the Administrator also awarded compensation for the 20% permanent partial disability under Section 18 of the WCA. The company contested this third award, arguing the Labor Administrator lacked jurisdiction to make an award without a formal hearing and that Section 18 was inapplicable. The Workmen’s Compensation Commission affirmed the award, prompting this certiorari petition.

ISSUE

1. Did the Labor Administrator act without jurisdiction by making an award without a formal hearing?
2. Was the award under Section 18 of the Workmen’s Compensation Act proper for Santiago’s injury?

RULING

The Supreme Court dismissed the petition and affirmed the Commission’s decision. On the jurisdictional issue, the Court ruled the Labor Administrator acted properly. The petitioner had expressly informed the Hearing Officer it was not controverting the claim. Under the Commission’s rules, such failure to controvert results in a renunciation of the right to contest, allowing the Hearing Officer to treat the claim as uncontested and make an award based on the records without further evidence. Thus, no abuse of discretion occurred.
On the applicability of Section 18, the Court rejected the petitioner’s narrow interpretation that the section, titled “Amputation,” applied only to literal limb loss. A cursory reading shows it encompasses other disabilities, including serious disfigurement and, under its fourth paragraph, “all other cases of this kind of disability not mentioned in other sections of this Act.” Santiago’s compression fracture and resulting permanent partial back disability, certified by the company’s own physician, is a disability akin to those contemplated by the section and not covered elsewhere in the law.
The Court also rejected the argument that compensation was uncomputable because Santiago received the same wages post-injury. The legal criterion is impairment of earning capacity, not merely wages received. Post-injury wages can be influenced by extraneous factors and do not negate the existence of a permanent physical impairment. The finding of a 20% permanent partial disability was a factual determination by the Commission, supported by medical evidence, which the Court could not review on certiorari. The WCA must be construed liberally in favor of the employee.