Forteza v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Amadeo R. Forteza, a watchman for the Philippine Charity Sweepstakes Office (PCSO) from July 1, 1950, to January 17, 1955, died of cerebral hemorrhage secondary to arteriosclerotic hypertension vascular disease. He was over 60 years old and had pre-existing hypertension when hired, making him a poor insurance risk. His duties included guarding PCSO properties, recording entries, closing windows, and patrolling the building, which involved moving between floors. He was found slumped near his station and died the following day. His widow received benefits under the Revised Administrative Code but sought further compensation under the Workmen's Compensation Act. Procedural History: The petitioner, Milagros F. Vda. de Forteza, filed a claim for death compensation benefits under Act 3428, as amended, and burial expenses. A Hearing Officer of the Regional Office No. 4, Department of Labor, initially awarded P2,575.36 in death benefits and P312.00 for burial expenses. The PCSO petitioned for review, raising issues of jurisdiction, lack of causal relation between the ailment and work, and prescription of the claim. The Hearing Officer denied this petition. Subsequently, the case was elevated to the Workmen's Compensation Commission, which reversed the Hearing Officer's decision, absolving the PCSO. A motion for reconsideration by the petitioner was also denied, leading to the present appeal. The Petition: The petitioner appeals to the Supreme Court, arguing that her deceased husband's hypertension was aggravated by the nature of his work, thereby hastening the fatal stroke. She contends that his duties, including nighttime work, exposure to cold, inadequate rest, and the physical exertion of patrolling a multi-story building, contributed to his death. The respondents argue that hypertension is not an occupational disease for a watchman and that the employee's five years of service without a prior stroke suggest no causal link. The petitioner relies on the presumption under Section 43(1) of the Workmen's Compensation Act, asserting that the employer failed to provide substantial evidence to disprove the causal connection between the employment and the death.
Issue(s)
Whether the death of Amadeo R. Forteza from cerebral hemorrhage secondary to hypertension is compensable under Act 3428, as amended. Whether the petitioner and her children are entitled to death compensation benefits under Section 2 of Act 3428, as amended.
Ruling
The Supreme Court reversed the decision of the Workmen's Compensation Commission and reinstated the decision of the Hearing Officer, ordering the Philippine Charity Sweepstakes Office to pay Milagros F. Vda. de Forteza the total amount of P2,575.36 as death compensation benefits and reimbursement for burial expenses.
Ratio Decidendi
On the compensability of the death under Act 3428: The Court held that the petitioner's contention must be upheld. The deceased's working conditions, including working at night, exposure to colds, inadequate rest, and tension due to guarding duties, coupled with his pre-existing minimal tuberculosis, could have aggravated or contributed to the cerebral stroke that caused his death. The fact that the stroke occurred near his working table while performing his duties further supports the claim that his death was in the course of employment and brought about, at least in part, by the strenuous nature of his work. The Court emphasized the presumption under Section 43(1) of Act 3428, which states that a claim comes within the provisions of the Act in the absence of substantial evidence to the contrary. This presumption requires the employer to prove that the death was not caused or aggravated by the employment, not merely the absence of proof that it was traceable to the employment. The Court cited Naira vs. Workmen's Compensation Commission and Batangas Trans. Co. vs. Vda. de Rivero, holding that even if the cause of death is unknown, it is compensable if it supervened in the course of employment. It is sufficient that the employment contributed to the aggravation or acceleration of the ailment leading to death. On the entitlement to death compensation benefits: The Court agreed with the Hearing Officer's computation of benefits. Under Section 8(a) of Act 3428, the widow is entitled to 45% of the average weekly wage for 208 weeks. The average weekly wage was P25.38 (P1,320.00 ÷ 52 weeks), entitling the widow to P11.42 weekly, totaling P2,375.36 for 208 weeks. Additionally, under the first paragraph of Section 8, the widow is entitled to reimbursement of burial expenses not exceeding P200.00, despite spending P312.00. Therefore, the total benefits awarded were P2,375.36 plus P200.00, amounting to P2,575.36.
Main Doctrine
The death of an employee due to an illness, even if pre-existing, is compensable under the Workmen's Compensation Act if the nature of the employment aggravated or contributed to the acceleration of the illness, leading to death. The presumption under Section 43(1) of Act 3428 applies, requiring the employer to prove that the death was not caused or aggravated by the employment.