G.R. No. L-41886. January 31, 1977.
RAMON CASTRO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and BUREAU OF PUBLIC SCHOOLS, respondents.

FACTS

Petitioner Ramon Castro, a classroom teacher, was diagnosed with minimal pulmonary tuberculosis in his left lung, as confirmed by an X-ray on June 6, 1972. He underwent medical treatment from March to June 1972 and subsequently stopped working on July 3, 1972, due to the persistence of his illness. He filed for sick leave and notified his employer, the Bureau of Public Schools, about his condition. He continued to receive medical treatment and check-ups from various physicians until his condition worsened, preventing his return to work.
On February 19, 1974, Castro filed a claim for compensation. The Regional Office dismissed the claim for being filed beyond the reglementary period under Section 24 of the Workmen’s Compensation Act. The Workmen’s Compensation Commission sustained the dismissal on review, holding that the Physician’s Report alone was insufficient evidence and that Castro failed to substantiate his claim with concrete proof like an X-ray report. Castro filed a motion for reconsideration, which the Commission did not act upon, instead issuing a letter instructing him to comply with certain administrative orders.

ISSUE

The primary issues are: (1) whether the petition for review is procedurally proper despite a pending motion for reconsideration; and (2) whether Castro’s illness is compensable and his claim should be granted despite the late filing.

RULING

The Supreme Court granted the petition, setting aside the Commission’s decision. On the procedural issue, the Court relaxed the rule requiring a final order from the Commission before judicial review, citing exceptional circumstances. The Commission was in its final months of existence, swamped with cases, and its directive to comply with administrative instructions was effectively a denial of the motion. Relaxing the rule promoted substantial justice and the speedy disposition of the case.
On the substantive issue, the Court ruled the illness compensable and the claim not barred. Pulmonary tuberculosis is a compensable occupational disease under the law, presumed to be work-related or aggravated by employment. The employer failed to rebut this presumption. Knowledge of the illness by the employer, demonstrated through Castro’s sick leave application and notification, constitutes a waiver of the right to contest the claim on grounds of non-jurisdiction or late filing. The constitutional guarantee of social justice mandates protection for employees who contract illnesses in the course of employment. The Bureau of Public Schools was ordered to pay Castro compensation benefits, medical expenses, attorney’s fees, and to provide continuous medical services.