Camarillo v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Raymundo I. Camarillo was employed by respondent Firestone Tire & Rubber Company of the Philippines for almost twenty-four years, holding various positions, the latest being Traffic Manager. In August 1971, a strike was staged by the employees' union, which continued for almost a year. During the strike, petitioner could not avail himself of the assistance of other personnel, leading to an increase in his workload and stress. Consequently, his health deteriorated, and he was confined in St. Luke's Hospital for two months starting October 7, 1971. Upon resuming work, he had a relapse due to the continued responsibilities. On May 10, 1972, he was diagnosed with "Nervous depression leading to neurosis, Rosteria Psycho-Asthenia" and was subsequently confined in San Juan de Dios Hospital on two occasions. Procedural History: On April 24, 1973, petitioner filed a Notice of Injury or Sickness and Claim for Compensation. The private respondent filed no controversion. On July 15, 1975, the Acting Referee rendered a decision ordering the private respondent to pay petitioner disability compensation, reimbursement of medical expenses, and attorney's and administrative fees. The Workmen's Compensation Commission reversed this award, dismissing the claim on the ground that the claimant failed to satisfactorily establish a condition linked to his occupation or a hazard distinguishing it from usual occupations. The Petition: Petitioner sought a review of the decision of the Workmen's Compensation Commission which reversed the award granted by the Acting Referee.
Issue(s)
Whether the illness of the petitioner supervened in the course of his employment. Whether the illness arose out of or was aggravated by his employment. Whether the employer successfully discharged the burden of proof to overthrow the presumption of compensability. Whether the failure to controvert the claim is fatal to the employer's defense.
Ruling
The decision of the respondent Commission is set aside, and the award made by the Acting Referee in favor of the petitioner is reinstated.
Ratio Decidendi
On the issue of whether the illness of the petitioner supervened in the course of his employment: The Court found that the illness of the petitioner did indeed supervene in the course of his employment. The Physician's Report, signed by Dr. Feliciano Dy, categorically stated that the illness arose as a consequence of the nature of the work and in pursuit thereof. This factual finding is crucial for the application of the Workmen's Compensation Act. On the issue of whether the illness arose out of or was aggravated by his employment: The Court reiterated its long-standing ruling that once an illness supervenes in the course of employment, a rebuttable presumption arises that such illness arose out of or was at least aggravated by the employment. This presumption is established by law and jurisprudence, requiring substantial evidence to the contrary. On the issue of whether the employer successfully discharged the burden of proof to overthrow the presumption of compensability: The Court held that the respondent Company failed to discharge this burden. The employer did not present any substantial evidence to prove that the illness was not work-related or aggravated by the employment. The burden to overthrow the presumption of compensability rests squarely on the employer, and in this case, it was not met. On the issue of whether the failure to controvert the claim is fatal to the employer's defense: The Court affirmed that pursuant to the mandate of the law, the absence of controversion is fatal to any defense that the employer could interpose. This failure to controvert the claim is constructively considered an admission that the claim is compensable. Therefore, the petitioner's claim for compensation should be granted.
Main Doctrine
Once an illness supervenes in the course of employment, a rebuttable presumption arises that it arose out of or was aggravated by such employment, and the burden to overthrow this presumption shifts to the employer. Failure to controvert the claim is fatal to any defense the employer could interpose, constituting an admission that the claim is compensable.