G.R. No. L-18532; August 31, 1963
BATANGAS TRANSPORTATION COMPANY, petitioner, vs. NARCISO VALENZUELA and THE WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Respondent Narciso Valenzuela, a bus driver for petitioner Batangas Transportation Company, was injured on November 17, 1958, when a non-employee operated his vehicle, pinning him against a wall. The petitioner conceded the injury was compensable but disputed the duration of disability and the resulting compensation amount. The company’s report and the attending physician’s initial assessment indicated a temporary total disability lasting only three to four weeks, from November 17 to around December 10, 1958. Valenzuela, however, claimed disability until June 11, 1959, supported by a subsequent medical certificate (Exhibit A) from the same hospital. The Hearing Officer awarded compensation for the longer period, admitting Exhibit A as a hospital record under the Workmen’s Compensation Act. The Workmen’s Compensation Commission affirmed this award and additionally granted attorney’s fees to Valenzuela, which the Hearing Officer had not originally provided.

ISSUE

The primary issues were whether the Workmen’s Compensation Commission erred in: (1) finding that Valenzuela’s temporary total disability lasted from November 17, 1958, to June 11, 1959, based on Exhibit A; and (2) awarding attorney’s fees despite Valenzuela not appealing the initial decision which omitted such an award.

RULING

The Supreme Court affirmed the Commission’s decision. On the first issue, the Court upheld the admissibility and probative value of Exhibit A as a hospital record under Section 49 of the Workmen’s Compensation Act, which permits the Commission to consider such evidence. The duration of disability is a factual finding, which is generally conclusive and binding upon the Court when supported by substantial evidence. Here, the Commission reasonably concluded that the initial 3-4 week estimate was inconsistent with the gravity of the injury, and the hospital record from June 1959 provided substantial evidence for the extended disability period. On the second issue, the Court ruled that the Commission properly awarded attorney’s fees motu proprio. Both the Workmen’s Compensation Act and the Civil Code authorize such awards based on equity. The absence of an appeal on that point is immaterial, as established in Fores v. Miranda, where appellate courts may award attorney’s fees as part of actual damages when just and equitable. Therefore, the award was legally sound.