G.R. No. L-24657 November 27, 1967
CALTEX (PHILIPPINES), INC., petitioner, vs. VICTORIANO D. CASTILLO and WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Respondent Victoriano D. Castillo was employed by petitioner Caltex (Philippines), Inc. starting in 1954. He initially worked as a TEL (Tetraethyl Lead) Blending Operator in the ethylizing plant, blending a poisonous substance (ethyl fluid) with gasoline. In 1956, he was transferred to another section due to complaints of body weakness and dizziness. On January 14, 1956, he was first found to be suffering from Thrombo-phlebitis. His condition, which also included varicose veins and allergic dermatitis, worsened over time, leading to periods of disability from work in 1962. He was examined by Dr. Prospero Ma. Oreta, to whom he was referred by the company physician, and was diagnosed with “Thrombo-phlebitis, chronic, legs bil.; varicose ulcer, leg right, edema, acute leg right; allergic dermatitis, leg right.” Dr. Oreta testified that the allergic dermatitis was probably due to prolonged and continuous contact with tetraethyl lead. Due to his impaired capacity, Castillo was prevailed upon to retire under the company’s retirement plan on March 7, 1964. He incurred medical expenses personally. The Hearing Officer of the Workmen’s Compensation Commission held petitioner liable for compensation. On review, the Commission affirmed the liability and awarded compensation for specific disability periods, reimbursement for medical expenses, and continued medical services, and also granted additional compensation for disability from the date of retirement (March 7, 1964) onward, subject to a statutory limit. Petitioner appealed, arguing a denial of due process, claiming the finding that the ailments were work-connected was unsupported by evidence and that the additional compensation for post-retirement disability was granted without a claim being presented and without a hearing.

ISSUE

1. Whether the finding of the Workmen’s Compensation Commission that respondent Castillo’s ailments were work-connected is supported by evidence.
2. Whether the grant of additional compensation for disability from March 7, 1964, onward, without a specific claim for such period and without a hearing, constitutes a denial of due process.

RULING

1. Yes. The Supreme Court affirmed the Commission’s finding. The Court is bound by the factual findings of the Workmen’s Compensation Commission absent a grave abuse of discretion due to a total absence of competent evidence. The testimony of Dr. Oreta, the expert witness to whom the company physician referred Castillo, provided substantial evidence linking the dermatitis to prolonged exposure to tetraethyl lead. Furthermore, under Section 44 of the Workmen’s Compensation Act ( Act No. 3428 , as amended), once an illness supervenes during employment, a rebuttable presumption arises that it arose out of or was aggravated by the employment. Petitioner failed to present substantial evidence to rebut this presumption.
2. No. The grant of additional compensation did not constitute a denial of due process. While the award covered a period beyond the original claim, the petitioner was not entirely deprived of an opportunity to be heard. The essence of due process is fairness and the absence of arbitrariness. The Court noted that petitioner did not demonstrate in its motion for reconsideration or brief that the result would have been different had it been specifically heard on the additional period. The substance of due process was satisfied. The decision of the Workmen’s Compensation Commission was affirmed.