G.R. No. L-43292. March 18, 1987.
MAURICIO BELLO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, BENEDICTO DINGLASAN & SONS, INC. AND HECTOR LAGMAN, respondents.

FACTS

Petitioner Mauricio Bello, an employee of jeepney operator Hector Lagman, filed a claim for disability compensation. He was diagnosed with “pulmonary tuberculosis, chronic, moderately advanced” and bacterial conjunctivitis. His attending physician certified that his illness was aggravated by his employment. Bello was confined at the Quezon Institute from May 27 to June 20, 1971, and again from September 20 to October 16, 1974. The Acting Chief of the Workmen’s Compensation Section initially awarded Bello P796.80 plus weekly compensation, but this was set aside upon Lagman’s motion.
The Workmen’s Compensation Commission, while applying the legal presumption of compensability under the law, granted only a lump sum of P178.28. This amount represented temporary total disability benefits solely for the exact periods of his hospital confinement in 1971 and 1974. The Commission absolved Benedicto Dinglasan & Sons, Inc., holding Lagman liable as the employer. Bello sought review, arguing for full compensation benefits.

ISSUE

Whether the respondent Commission erred in granting only a minimal lump sum award for specific confinement periods instead of full disability compensation benefits for Bello’s tuberculosis.

RULING

The Supreme Court granted the petition and awarded full compensation. The legal logic centered on the compensability of tuberculosis as an occupational disease and the proper assessment of disability. The Court held that the Commission erred by limiting the award to the exact days of hospitalization. Medical certifications from Bello’s physicians and the Quezon Institute established that his tuberculosis was a recurring condition, not merely episodic during confinement. Under Section 2 of the Workmen’s Compensation Act, an illness directly caused or aggravated by employment is compensable.
The Court emphasized that laboratory reports, like x-rays, are not indispensable for compensability. The physician’s certification, absent evidence of falsity, is sufficient. The technical absence of an x-ray report cannot prejudice the claimant’s right. Furthermore, the principle of substantial justice over technicalities applies in workmen’s compensation cases. The meager award of P178.28 was deemed unrealistic and contrary to the social justice purpose of the law, as it failed to account for the ongoing debilitating nature of tuberculosis which rendered Bello incapable of pursuing his usual work. Consequently, the Commission’s decision was set aside. Respondent Hector Lagman was ordered to pay petitioner the maximum disability compensation of P6,000.00, plus attorney’s fees and costs.