Visayan Stevedore & Transportation Company v. Labiyo
REITERATIONFacts
The Antecedents: Eduardo Labiyo, an engineer employed by Visayan Stevedore & Transportation Company (VISTECO), was part of a 3-man crew on the tugboat "M/T DILIS." His duties included starting and ensuring the proper functioning of the engine. From February 10 to 17, 1964, the crew was engaged in towing barges and other related tasks, requiring them to stay on the tugboat. On February 17, 1964, at approximately 4:00 a.m., while towing barges, Labiyo, visibly tired, requested permission to rest. Upon reaching their destination, he was found dead in his bunk at approximately 6:30 a.m. A subsequent autopsy traced the cause of death to "bangungot." Procedural History: Julieta S. Labiyo, the widow, filed a claim for compensation. The acting referee of the Department of Labor dismissed the case, finding that the death did not arise out of or was aggravated by employment. The Workmen's Compensation Commission (WCC) set aside the referee's decision, ordering VISTECO to pay compensation benefits, burial expenses, and costs. VISTECO's motion for reconsideration was denied. The Petition: VISTECO appealed the WCC's decision, assailing the finding that Labiyo died due to "over fatigue or over exertion" and arguing that the autopsy result tracing the cause to "bangungot" was not supported. They contended that Labiyo could not have overexerted himself as he was not performing manual labor and that his work allowed ample rest.
Issue(s)
Whether the death of Eduardo Labiyo, attributed to "bangungot," is compensable under the Workmen's Compensation Act. Whether the WCC erred in concluding that Labiyo died due to "over fatigue or over exertion" despite the autopsy finding of "bangungot."
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, ordering petitioner Visayan Stevedore & Transportation Company to pay respondent Julieta S. Labiyo compensation benefits, burial expenses, and costs.
Ratio Decidendi
On the compensability of death attributed to "bangungot" and the presumption of compensability: The Court held that the main point pressed by the petitioner, namely, that death caused by "bangungot" is not compensable, was not decisive. Crucially, it was undisputed that Eduardo Labiyo was on active duty as an engineer-employee of the petitioner when death came to him. Under Section 44 of the Workmen's Compensation Act, as amended, there is a legal presumption that an employee's death, supervening during employment, either arose out of, or was at least aggravated by, said employment. This presumption shifts the burden of proof to the employer to demonstrate the contrary. The mere opinion of doctors presented by the petitioner cannot prevail over this legal presumption. The Court emphasized that the need to pinpoint the exact work-connected cause of death assumes little importance when the employee is on active duty. On the WCC's conclusion of "over fatigue or over exertion" versus the autopsy finding of "bangungot": The Court found that the petitioner's reliance on the autopsy finding of "bangungot" was misplaced in arguing for non-compensability. The Court noted that the petitioner's own cited case, Luzon Brokerage Co., Inc. vs. Dayao, et al., expressed doubt as to the soundness of the theory that "bangungot" by itself can be the cause of death, describing it as a "theoretical disease" whose causes and pathology are not scientifically established. The WCC's view that Labiyo died due to over fatigue or over exertion, or heart failure due to some factors, was supported by the fact that Labiyo requested to sleep at an early hour, indicating he was very tired due to continuous work from February 10 to 17. The Court reiterated that when an employee satisfies certain human wants, like sleeping, during the course of employment, and something happens that causes death, it should be considered as occurring in the course of employment, unless it is clearly shown that the mishap occurred because the employee acted beyond his duty or outside the course of employment. The petitioner failed to prove that death was not and could not be caused or aggravated by the deceased's work, especially considering he was practically on 24-hour continuous duty.
Main Doctrine
The death of an employee occurring during the time of employment is presumed to have arisen out of or at least been aggravated by said employment, shifting the burden of proof to the employer to show otherwise. The cause of death, even if medically unexplained like 'bangungot', does not negate compensability if the employee was on active duty at the time of death.