Justiniano v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Francisco Justiniano was employed as a sailor by Cebu Stevedoring Co., Inc. starting in 1946. On June 20, 1958, at 4:00 AM while on duty, he experienced pain in his head and left breast, and uneasiness in the left portion of his body, followed by the expulsion of a blood clot and bleeding from his nostrils. He was diagnosed with high blood pressure and confined in the hospital from June 20, 1958, to October 9, 1958. His illness resulted in hemiplegia (paralysis of the left side of his body), leading to his resignation. He filed a claim for compensation under the Workmen's Compensation Act. Procedural History: The hearing officer awarded compensation to Francisco Justiniano. However, the Workmen's Compensation Commission (WCC) reversed this decision, absolving the employer on the ground that the illness was not proven to have been caused or aggravated by the employment. A motion for reconsideration was denied by the WCC en banc. The Petition: Francisco Justiniano appealed the WCC's decision and resolution to the Supreme Court.
Issue(s)
Whether total disability due to paralysis caused by an illness (hypertension) supervening during employment is compensable without proof that the illness arose out of or was aggravated by the employment. Whether the WCC erred in ruling that compensation is not awardable without evidence proving the disease was caused or aggravated by the employment.
Ruling
The Supreme Court reversed the decision of the Workmen's Compensation Commission and ordered the employer to pay the claimant compensation for total disability, further medical expenses, and attorney's fees, along with administrative costs to the Workmen's Compensation Fund.
Ratio Decidendi
On the issue of compensability of supervening illness without direct proof of causation: The Court held that Section 44(1) of the Workmen's Compensation Act establishes a rebuttable presumption that an illness which supervenes during employment arises out of or is aggravated by said employment. This presumption relieves the claimant from the burden of proving causation once it is established that the illness occurred during the period of employment. The WCC's ruling that compensation is not awardable without such proof is contrary to this statutory presumption. The Court emphasized that the law presumes compensability in the absence of substantial evidence to the contrary. The claimant is relieved from the burden of proving causation once the illness is shown to have arisen in the course of employment. The presumption is that it arose out of it. Therefore, the decision refusing the award was reversed based on this legal presumption. On the WCC's error in requiring proof of causation: The Court found that the WCC's decision was not in consonance with Section 44(1) of the Workmen's Compensation Act. The WCC's stance that compensation requires proof of causation directly contradicts the established legal presumption. The Court cited its own ruling in the Agustin case, which clarified that the laborer is relieved from proving causation once the injury or illness arises in the course of employment, as the law presumes it arose out of it. The fact that the hypertensive attack occurred during the employee's "tour of duty" was undisputed, thus triggering the presumption.
Main Doctrine
Under Section 44(1) of the Workmen's Compensation Act, once an illness supervenes during employment, there is a rebuttable presumption that the illness arose out of or was aggravated by the employment, relieving the claimant from the burden of proving causation.