G.R. No. L-7310, December 28, 1957
ANTONIO MANIMTIM, plaintiff-appellant, vs. CO CHO CHIT, etc., defendant-appellee.

FACTS

Plaintiff-appellant Antonio Manimtim was an employee of defendant-appellee Co Cho Chit. On May 27, 1948, while sharpening an auger at work, a metal piece pierced his right eye, resulting in total loss of its vision after treatment. Defendant paid for hospital/doctor bills and wages during confinement. Subsequently, plaintiff began experiencing pain and dimness in his left eye. Medical examinations by the Bureau of Labor, including a negative Kahn’s test for syphilis, led Dr. Alfredo Gorospe to conclude the left eye’s blindness was due to sympathetic ophthalmia (transferred infection from the injured right eye). Meanwhile, in July 1948, defendant, through his lawyer, presented a release agreement (Exhibit X) for plaintiff to sign, settling the claim for the right eye for P1,402.47. Plaintiff signed upon assurance from a Bureau official that the payment was only for the right eye, while his left eye claim was still being processed. This agreement contained a waiver of all future claims from the accident. It was signed on July 14, 1948, but notarized much later on March 2, 1949. Plaintiff filed an action to recover P1,446 as unpaid compensation for the loss of sight of his left eye. Both the Municipal Court and the Court of First Instance of Manila dismissed the case, relying on the release agreement and questioning Dr. Gorospe’s expertise.

ISSUE

1. Whether the defendant is liable for compensation for the loss of sight of the plaintiff’s left eye, which allegedly resulted from the injury to his right eye.
2. Whether the release agreement (Exhibit X) bars the plaintiff’s claim for additional compensation for the left eye.

RULING

1. Yes, the defendant is liable. The Supreme Court found that the loss of vision of the left eye was due to sympathetic ophthalmia, a transferred infection from the injured right eye, as established by the unrefuted testimony of Dr. Gorospe. This condition is a direct and natural consequence of the original work-related injury, making it compensable under the Workmen’s Compensation Act ( Act No. 3428 , as amended), which must be interpreted liberally to protect laborers.
2. No, the release agreement does not bar the claim. The Court found the agreement null and void under Section 7 of Act No. 3428 , which prohibits any contract intended to exempt the employer from liability created by the Act. Furthermore, the plaintiff signed the document under the honest belief, based on assurances, that it only settled the claim for his right eye, while he was already suffering from and pursuing a claim for his left eye. The timing of the notarization (after a formal amended demand including the left eye was made) also indicated the defendant’s intent to avoid further liability. Therefore, the agreement cannot exempt the defendant from additional compensation.
The decision of the lower court was reversed. Defendant was ordered to pay plaintiff the sum of P1,446.00, with costs.