G.R. No. L-23762, August 31, 1970
Rosario Vargas, Petitioner, v. Philippine American Embroideries, Inc. and The Hon. Baens Del Rosario as Chairman of the Workmen’s Compensation Commission, Respondents.

FACTS

Petitioner Rosario Vargas was employed as a brassiere sewer by respondent Philippine American Embroideries, Inc. On July 19, 1961, she was advised by the company to take a three-month rest due to pulmonary infection, diagnosed as moderately advanced, active, bilateral PTB. A Workmen’s Compensation Act referee granted her disability benefits on January 7, 1963, finding that while her tuberculosis was not directly caused by her work, it was aggravated by her heavy workload (a daily quota of 360 brassieres) and by working in a crowded, ill-ventilated area housing 100 workers. On December 24, 1963, the Chairman of the Workmen’s Compensation Commission reversed this decision, ruling her work was light and sedentary and that she failed to prove aggravation. The Commission affirmed this on October 13, 1964. On November 5, 1964, the last day of the reglementary period, Vargas filed a petition for review with the Supreme Court and served copies on the Commission and the Company but failed to file a separate notice of appeal with the Commission.

ISSUE

1. Whether the petitioner perfected her appeal to the Supreme Court despite not filing a notice of appeal with the Workmen’s Compensation Commission.
2. Whether her tuberculosis was caused or aggravated by the nature of her work.

RULING

1. Yes, the appeal was perfected. The Supreme Court held that under Section 1 of Rule 43 of the new Rules of Court, the filing of a notice of appeal with the Commission is no longer a compulsory requirement for perfecting an appeal. The timely filing of a petition for review with the Supreme Court and service upon the adverse parties substantially complies with the procedural requirement. The petition for review itself sufficiently expresses the intention to appeal, rendering a separate notice of appeal a mere technicality.
2. Yes, her illness was aggravated by her employment. The Court found that the petitioner’s workload was heavy, not light, as she had to meet a strict daily quota under pressure. Furthermore, the working conditions were unhealthful and insanitary—a congested, ill-ventilated “sweatshop” environment that promoted the spread of tuberculosis. These factors constituted sufficient substantial evidence that her pre-existing tuberculosis was aggravated by the nature and conditions of her employment.
The decision of the Commission was set aside. The respondent company was ordered to pay the petitioner disability compensation, medical expenses, attorney’s fees, and costs.