Naira v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Juan Naira was employed by Compania General de Tabacos de Filipinas for 26 years, working as a barge pilot and assisting in loading and unloading cargoes. On November 12, 1958, he worked until 1:30 p.m., helping load the barge with heavy barrels, which required three persons, including himself, to carry them one at a time. After returning to work at 2:00 p.m., he complained of stomachache, was brought to a clinic, and subsequently to the Isabela Provincial Hospital, where he died the next day. The attending physician diagnosed his illness as acute mesenteric thrombosis, confirmed by autopsy. Procedural History: The claimant-widow averred her husband died of pulmonary tuberculosis or acute beriberi, submitting a death certificate to that effect. However, the Workmen's Compensation Commission (WCC) concluded, based on the autopsy report, that the cause of death was acute mesenteric thrombosis. The WCC denied compensation, stating that the claimant failed to show that the acute mesenteric thrombosis was directly caused by, aggravated by, or the result of the nature of the employment, and that there was no evidence linking the illness with the nature of his work. The Petition: The claimant-widow resorted to the Supreme Court for review after her motion for reconsideration was denied.
Issue(s)
Whether the Workmen's Compensation Commission erred in denying compensation by requiring the claimant to prove direct causation or aggravation of the illness by the employment, thereby ignoring the presumption of compensability under Section 43(1) of the Workmen's Compensation Act. Whether the illness of acute mesenteric thrombosis, which supervened during the course of employment and followed closely the physical exertion of loading heavy cargoes, is compensable under the Workmen's Compensation Act.
Ruling
The decision of the Workmen's Compensation Commission is reversed. The case is remanded to the Commission for determination of the amount of compensation due the petitioner and the other heirs of the deceased worker.
Ratio Decidendi
On the presumption of compensability: The Supreme Court held that the Workmen's Compensation Commission erred in demanding that the claimant establish direct causation or aggravation of the illness by the employment. The Commission ignored the presumption expressly established in Section 43(1) of the Workmen's Compensation Act (No. 3428), as amended by Republic Act 772. This section presumes, in the absence of substantial evidence to the contrary, that the claim comes within the provisions of the Act. Therefore, the burden was on the employer to prove that the illness was not caused or aggravated by the employment, not on the claimant to prove that it was. The mere absence of evidence tracing the mishap to the employment is insufficient to reject the claim; there must be credible showing that it was not so traceable. The Court cited Batangas Trans. Co. vs. Vda. de Rivera and Bohol Land Trans. Co. vs. Vda. de Madanguit in support of this principle. The Court further noted that in Batangas Transportation, it was held that where the cause of death supervening in the course of employment is unknown, the death is compensable, reinforcing the idea that the employer must present substantial evidence to rebut the presumption. On the compensability of acute mesenteric thrombosis: The Court found that the illness followed closely the exertions of the deceased in unloading the employer's barge, which involved carrying heavy barrels. This factual circumstance strongly supports the inference that the thrombosis leading to his death was at least precipitated by strain. Given the presumption of compensability and the factual context linking the physical exertion to the onset of the illness, the claim should have been considered compensable. The employer failed to present substantial evidence to overcome the presumption that the death was work-related or aggravated by the nature of the employment.
Main Doctrine
In claims for compensation under the Workmen's Compensation Act, there is a legal presumption that the claim comes within the provisions of the Act, and the burden is on the employer to prove by substantial evidence that the injury or death was not caused or aggravated by the employment. The mere absence of evidence tracing the illness to the employment is insufficient to reject a claim; there must be credible proof that it was not so traceable.