Leopoldo Lorenzo vs Workmen’s Compensation Commission

G.R. No. L-42631 – 81 SCRA 434 – Civil Law – Preliminary Title – Waiver of Rights

Leopoldo Lorenzo worked as a molder for the Philippine Glass Manufacturing Company starting in 1964. In early 1974, Lorenzo applied for SSS sickness benefits. SSS then required Lorenzo to be confined in various occasions. In August 1974, while at work, he complained of chest pains. He made known to a company manager his condition. On October 4, 1974, PGMC ceased operation due to lack of fuel. On the same day, Lorenzo stopped working.

On October 7, 1974, Lorenzo was diagnosed with tuberculosis. Later, Lorenzo filed for compensation benefits as he averred that his TB was work related. The DOLE Regional Office denied his claim as the DOLE-RO ruled that Lorenzo was never disabled because in fact he was working until PGMC closed. The Workmen’s Compensation Commission affirmed the DOLE-RO ruling.

ISSUE: Whether or not Lorenzo is entitled to compensation benefits.

HELD: Yes. The Supreme Court ruled that there is enough evidence to support Lorenzo’s claim that his TB was work related [i.e., the SSS mandated hospital confinements]. The SC also ruled that PGMC failed to controvert Lorenzo’s claim for sickness benefits. Such failure to controvert the right of claimant to compensation benefits within the statutory period amounted to a waiver or renunciation of the said right. As per the record, PGMC already knew of Lorenzo’s sickness claim as early as February 1974 when SSS required Lorenzo to be confined. In August 1974, Lorenzo again notified a PGMC manager about his condition. It was only in May 1975 that PGMC controverted Lorenzo’s claim.

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