GR L 42914; (March, 1985) (Digest)
G.R. No. L-42914. March 29, 1985.
RODOLFO CEPEDA, claimant-appellant, PATRICIA LUNA and FELIPE CEPEDA, petitioners, vs. BACOLOD MURCIA MILLING CO., INC., and/or WORKMEN’S COMPENSATION COMMISSION, respondents-appellees.
FACTS
Rodolfo Cepeda worked for Bacolod Murcia Milling Co., Inc. from 1965 as a basketman, involving constant exposure to heat, dust, and strenuous physical effort. In March 1970, he was forced to stop working due to symptoms including chronic cough, dizziness, and weakness, as advised by the company physician. Despite treatment, his condition persisted, preventing his return to work.
Cepeda filed a compensation claim on March 31, 1975. Medical evidence, including x-ray reports from 1972 to 1975, diagnosed his condition as pulmonary tuberculosis, progressing from “minimal questionably active” to “far advanced, active.” The Workmen’s Compensation Unit awarded compensation, but the Workmen’s Compensation Commission reversed this, ruling the claimant failed to prove his illness existed at the time he stopped working in 1970, as the medical reports were dated years later.
ISSUE
Whether the claimant’s illness is compensable under the Workmen’s Compensation Act despite the absence of medical evidence contemporaneous with his cessation of work in 1970.
RULING
Yes. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic is anchored on the non-applicability of strict rules of evidence in compensation proceedings. Probability, not certainty, is the standard for establishing the work-connection of an illness. Tuberculosis is an imperceptible, progressive disease that manifests long after initial infection; its advanced stage years after employment does not negate its contraction during employment.
The Court emphasized that x-ray reports are not indispensable, and the nature of the claimant’s arduous work, with its exposures, establishes the probable work-connection. Furthermore, the employer’s failure to timely controvert the claim constituted a waiver of defenses, including any challenge to the timeliness of the filing. The claim, filed within the ten-year prescriptive period from the date of disability under the then-governing Workmen’s Compensation Act, was thus valid. The compensation is a vested statutory liability.