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Leopoldo Lorenzo vs Workmen’s Compensation Commission

November 5, 2010

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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 claim for sickness benefits. Such failure to controvert 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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