G.R. No. L-29670 October 9, 1987
CENTRAL AZUCARERA DON PEDRO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and NEMESIO TANIO, respondents.

FACTS

Nemesio Tanio worked for Central Azucarera Don Pedro, starting as a laborer and later as a machine operator. He stopped working on February 9, 1960, after allegedly spitting blood. The company physician diagnosed him with minimal pulmonary tuberculosis (PTB). He was confined at the company hospital for three days under a collective bargaining agreement but then refused further treatment, requested discharge, and opted for retirement, receiving a P400 gratuity. He later executed an affidavit confirming his voluntary refusal of treatment. Three years later, on October 8, 1963, Tanio filed a claim for disability compensation and medical reimbursement with Regional Office No. 4 in Manila. The Hearing Officer dismissed the claim for lack of merit, but the Workmen’s Compensation Commission reversed this, awarding compensation, medical reimbursement, attorney’s fees, and ordering continued medical services.

ISSUE

The primary issues were: (1) whether Regional Office No. 4 in Manila had jurisdiction over the claim; (2) whether Tanio’s claim was barred for failure to give timely notice under the Workmen’s Compensation Act; (3) whether minimal PTB was compensable; (4) whether Tanio was entitled to reimbursement for medical expenses despite refusing treatment; and (5) whether attorney’s fees were correctly awarded without a specific prayer.

RULING

The Supreme Court affirmed the Commission’s decision with modification. On jurisdiction, the claimant’s choice of venue under the rules was upheld, as Tanio was residing in Manila at the time of filing, making Regional Office No. 4 proper. On prescription and notice, the Court ruled the claim was not barred. The employer’s act of providing and paying for initial medical treatment obviated the need for formal notice under Section 24 of the Act, and the ten-year prescriptive period applied. On compensability, minimal PTB was deemed compensable under the presumption that an illness occurring during employment is work-related, which the employer failed to rebut. However, the award for medical expense reimbursement and the order for continued medical services were deleted because Tanio unreasonably refused the medical treatment proffered by the employer, which abated his right to such benefits under the Act. The award of attorney’s fees was sustained as it was made integral to compensation benefits by statutory amendment, requiring no specific prayer or proof. Costs were imposed on the petitioner.