Muradyan, Armen

Applicant Armen Muradyan, a truck driver, sustained a back injury while employed by AJR Trucking and was found 100% permanently disabled in a January 22, 2024 Findings and Award. Defendant Insurance Company of the West filed a Petition for Reconsideration arguing it should specifically be awarded credit for permanent disability advances (PDA) it paid, citing Labor Code section 4909. The WCAB granted reconsideration and amended the F&A to expressly provide defendant credit for amounts previously paid, to be adjusted by the parties with jurisdiction reserved at the trial level for any dispute. The Board agreed with the WCJ that section 4909 does not apply because the PDAs were undisputed advances on benefits later found to be due, not voluntary payments of benefits later found not owing.