G.R. No. L-19612; July 30, 1964
PETER PAUL PHILIPPINE CORPORATION, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, ET AL., respondents.

FACTS

Lorenzo Castro was employed as a coconut sheller by Peter Paul Philippine Corporation in 1947. His work, performed on a piece-rate (“pakiao”) basis, involved manually extracting meat from coconuts with a knife. Periodic X-rays showed him in good health until February 1954, when he was diagnosed with pulmonary tuberculosis in his left lung, forcing him to stop work. He was treated by the company physician and later by a private doctor. In March 1954, he was separated from service and received separation pay. On March 11, 1955, he filed a claim for compensation with the Workmen’s Compensation Commission.
The hearing officer initially dismissed the claim, finding the illness was not caused or aggravated by his employment. On review, the Commission en banc reversed, ruling the ailment was compensable. The employer moved for reconsideration, arguing the claim was filed beyond the two-month period prescribed by Section 24 of the Workmen’s Compensation Act. The Commission denied the motion, prompting this petition for review.

ISSUE

The primary issues are: (1) Whether Castro’s tuberculosis is compensable as having been contracted due to the nature of his employment; and (2) Whether his claim was filed beyond the statutory period, thereby barring recovery.

RULING

The Supreme Court affirmed the Commission’s decision, holding the claim compensable and not barred by prescription. On compensability, the Court upheld the Commission’s factual finding that the nature of Castro’s work contributed to the activation of his tuberculosis. The Commission described shelling as strenuous labor, requiring rapid, continuous exertion to meet quotas, often performed on night shifts, which placed excessive strain on the worker’s health. This finding, based on substantial evidence including an ocular inspection report from a similar case, is conclusive. The law presumes, in the absence of substantial evidence to the contrary, that a claim is compensable if the illness supervenes during employment.
On the issue of prescription, the Court rejected the employer’s argument that the two-month period under Section 24 should run from the date the illness was contracted. The Court adopted a reasonable interpretation: the period should be counted from the date the illness becomes compensable, i.e., from the date it results in disability affecting earning capacity. Castro’s disability began when he stopped work in February 1954 and was separated in March 1954; his claim filed in March 1955 was thus beyond the two-month limit. However, the claim was saved from prescription under the exception provided by the Act. The employer’s payment of separation pay (P100.90) and a compensation amount (P91.21) constituted a voluntary payment that dispensed with the requirement of filing the claim within the statutory period. Therefore, the Commission correctly entertained the claim.