Catibog v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Socorro J. Catibog, employed by the Bureau of Public Schools for approximately 43 years, filed a claim for compensation benefits under Republic Act No. 3428 due to physical disability from hypertensive heart disease with left ventricular hypertrophy, hypercholesterolemia, and angina pectoris. She experienced symptoms since July 1974, took sick leaves, and on September 7, 1974, stopped working upon her physician's recommendation, subsequently retiring on disability effective December 20, 1974. She died on May 1, 1976, due to Coronary Thrombosis and Hypertension. Procedural History: The Department of Labor Regional Office No. 5 initially awarded the claim. Upon motion for reconsideration, the case was elevated to the Workmen's Compensation Commission (WCC). The WCC reversed the Acting Referee's decision, absolving the respondent Bureau of Public Schools from liability. The Petition: The heirs of Socorro J. Catibog appealed the WCC decision to the Supreme Court.
Issue(s)
Whether the Workmen's Compensation Commission erred in reversing the decision of the Department of Labor Regional Office No. 5 and absolving the respondent Bureau of Public Schools from liability. Whether the illness of Socorro J. Catibog was work-connected or aggravated by her employment, thus entitling her heirs to compensation benefits.
Ruling
The Supreme Court reversed the decision of the Workmen's Compensation Commission. The respondent Bureau of Public Schools was directed to pay the heirs of Socorro J. Catibog disability and/or death benefits in the sum of P6,000.00, reimbursement for medical expenses in the sum of P441.10, and attorney's fees to Atty. Vedasto J. Hernandez in the sum of P622.10, plus administrative fees of P61.00.
Ratio Decidendi
On the issue of compensability of the illness: The Court held that the illness of Socorro J. Catibog was presumed to be work-connected or aggravated by her employment. The claimant had served the Bureau of Public Schools for approximately 43 years, and her illness began to manifest during her service. The Court reiterated the principle that under the Workmen's Compensation Act, an illness contracted during and in the course of employment is presumed to be work-connected, and the burden shifts to the employer to prove otherwise. The respondent failed to present evidence to rebut this presumption. The fact that the claimant retired due to disability does not diminish the compensability of her illness. Furthermore, the claimant's subsequent death due to coronary thrombosis and hypertension, which are related to her pre-existing condition, strengthened the presumption that her illness was work-related and aggravated during her long tenure. The Court cited Aurora C. Vda. de Leorna, etc. vs. Workmen's Compensation Commission, et al., L-42543, September 30, 1976, to support the conclusion that the death of the claimant strengthens the presumption of work-connection. On the procedural aspect of controversion: The Court noted that the respondent failed to controvert the claim seasonably, which resulted in the waiver of all non-jurisdictional defenses. This procedural lapse further supported the claim for compensation benefits. The Acting Referee's finding that the claimant must have been in good health when she entered government service and that her illness manifested only after almost 41 years of service was given weight. The Court emphasized that even if the work was not the sole factor, as long as it contributed even in a small degree to the development or acceleration of the disease, it is compensable, especially considering the mentally arduous nature of her work.
Main Doctrine
An illness contracted during and in the course of employment, particularly when the employee has served for a long period, is presumed to be work-connected or aggravated, and the employer bears the burden of proving otherwise. The death of the employee due to such illness further strengthens this presumption.