G.R. No. L-19522. August 31, 1964. BATANGAS TRANSPORTATION COMPANY, petitioner, vs. TOMAS PEREZ and THE WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS

Tomas Perez worked as a bus driver for Batangas Transportation Company from 1952 to 1958, plying a rough, dusty route with daily overtime. On January 20, 1957, while driving, his bus was bumped by another truck. Perez sustained contusions and abrasions but continued working. Soon after, he developed a severe cough and was treated by the company physician. On March 2, 1958, after an X-ray, he stopped work due to voice loss and weakness and was later diagnosed with pulmonary tuberculosis at the Quezon Institute. He was dismissed by the company in October 1958 for absence. Medical records indicated his condition was stationary as of April 1959.
The Workmen’s Compensation Commission affirmed a hearing officer’s award, ordering the company to pay Perez disability compensation and provide medical services. The Commission found that the accident injuries reduced his vitality, making him susceptible to the activation of latent tuberculosis, thus connecting the illness to his employment. The company appealed via certiorari, contesting the causal link, the award amount, the order for medical services, and an attorney’s fees award.

ISSUE

Whether the Workmen’s Compensation Commission committed grave abuse of discretion in awarding compensation and benefits to Tomas Perez for his pulmonary tuberculosis.

RULING

The Supreme Court affirmed the Commission’s award, deleting only the attorney’s fees. On the primary issue of compensability, the Court upheld the Commission’s factual finding that the illness resulted from the nature of Perez’s employment. While the tuberculosis was not directly caused by the work, the accident of January 1957, which occurred in the course of employment, established the requisite causal connection. The injuries from that accident “must have reduced his vitality and lowered his power of resistance,” thereby aggravating a latent condition or making him more susceptible to the disease. This falls under the Act’s coverage for illnesses “aggravated by the employment” or “the result of the nature of his employment.” The Court deferred to the Commission’s expertise on this factual conclusion, noting the Workmen’s Compensation Act is social legislation to be liberally construed in favor of the worker.
The Court also rejected the company’s argument that Perez’s disability had ceased by April 1959, as the Commission’s finding that the illness was not yet cured or arrested was supported by Perez’s own testimony about ongoing weakness and treatment. The order to provide continuing medical services was valid, and the claim that such an order required a current employer-employee relationship was deemed absurd, as it would allow employers to evade liability simply by dismissing ill employees.
However, the Court sustained the petitioner’s challenge to the P300 attorney’s fees award. Since Perez did not appeal from the hearing officer’s decision, the Commission, acting as an appellate body, could not grant him additional relief. Thus, this portion of the award was eliminated.