GR L 35818; (January, 1984) (Digest)
G.R. No. L-35818 January 31, 1984
JOSE P. FELARCA, petitioner, vs. BOOKMAN, INCORPORATED and WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
Petitioner Jose P. Felarca filed a claim for disability benefits under the Workmen’s Compensation Act on June 20, 1969. He alleged that his illness, progressive muscular atrophy, was contracted or aggravated during his 21-year employment as plant superintendent of respondent Bookman, Inc., a printing press company. His duties involved extensive manual labor and supervision, requiring constant use of his hands in operating machinery and lifting heavy molds. He first experienced symptoms in October 1968, consulted the company physician in November, and eventually retired on January 11, 1969, after which he was treated by a private physician. The employer controverted the claim, arguing the illness did not arise from employment and that the claim was barred by prescription. The Workmen’s Compensation Commission denied the claim, relying on medical testimony that the atrophy was a symptom caused by other specific conditions like leprosy or tumor.
ISSUE
The primary issues were: (1) whether petitioner’s illness arose out of or was aggravated by his employment, and (2) whether his claim was barred by prescription.
RULING
The Supreme Court reversed the Commission’s decision and granted the claim. On the first issue, the Court applied the rebuttable presumption under the Workmen’s Compensation Act that an illness which supervenes during employment is presumed to have arisen out of or been aggravated by such employment. This presumption, established in Magalona vs. Workmen’s Compensation Commission, places the burden on the employer to present substantial evidence to disconnect the illness from the work. Here, the Court found the employer failed to present such substantial evidence. It noted that, despite some variance in medical opinions, the testifying doctors largely agreed the nature of the claimant’s work aggravated his condition. The precise medical cause was deemed legally insignificant once the illness supervened in the course of employment.
Regarding prescription, the Court, citing Central Azucarera Don Pedro vs. Workmen’s Compensation Commission, ruled that delay in filing is a non-jurisdictional defect. The claim is not barred unless the employer demonstrates actual prejudice from the delay, a showing not made in this case. This approach aligns with the protective intent of the law towards laborers. Consequently, respondent Bookman, Inc. was ordered to pay petitioner P6,000.00 as compensation and the corresponding fee to the Workmen’s Compensation Fund.