BERNARDO BAMBALAN, petitioner, vs. WORKMEN’S COMPENSENCE COMMISSION and UNIVERSAL TEXTILES MILLS, INC., respondents.
FACTS
Petitioner Bernardo Bambalan, a machine operator for respondent Universal Textile Mills, Inc., filed a claim for sickness benefits with the Workmen’s Compensation Commission (WCC) for ailments of acute pyelonephritis and acute bronchitis allegedly suffered or aggravated by his employment. The WCC Unit Head initially dismissed the claim for failure of the parties to appear at a scheduled hearing. Upon review, the WCC affirmed the dismissal but on a different ground, finding an absence of substantial evidence and a lack of causal relation between the ailments and the petitioner’s employment.
The petitioner sought reconsideration, arguing he had submitted ample evidence, including a Notice of Injury, Physician’s Report, affidavits, and medical certificates detailing his illness, hospitalization, and the poor working conditions involving continuous standing, exposure to temperature changes, and cotton dust. He also emphasized that the respondent employer had failed to timely controvert his claim as required by law.
ISSUE
Whether the Workmen’s Compensation Commission erred in dismissing the petitioner’s claim for compensation benefits.
RULING
Yes. The Supreme Court granted the petition and reversed the WCC’s decision. The legal logic proceeds from two key principles of workmen’s compensation law. First, the technical rules of evidence do not strictly apply. The documents submitted by the petitioner constituted substantial evidence sufficient to establish a claim, and their rejection by the WCC for lacking formal credence was unjustified. The Physician’s Report and medical certificates, though hearsay, are admissible as hospital records under the Workmen’s Compensation Act.
Second, the respondent employer’s failure to timely controvert the claim is fatal to its defense. The record showed the company was notified of the ailment, as the petitioner sought treatment at the company clinic and was recommended for hospitalization by a company physician. This failure to controvert within the statutory period renders the claim compensable and its validity beyond challenge. Furthermore, the ailments are compensable as they supervened during employment. The nature of the petitioner’s work as a machine operator, involving prolonged standing, postponed urination, and inhalation of cotton dust, could reasonably have caused or aggravated acute pyelonephritis and acute bronchitis, following the Court’s reasoning in analogous cases. The Court thus ordered the respondent company to pay the petitioner compensation for temporary total disability plus attorney’s fees.
