Mercado v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Regalado Mercado began working as a weaver for Riverside Mills Corporation in 1963. In October 1973, he experienced stomach pains, later diagnosed as "cirrhosis of the liver; hyperdality, secondary to liver cirrhosis." Despite his ailment, he continued working until his condition worsened, leading to his death on October 31, 1974. Procedural History: On March 30, 1975, Regalado's widow, Calixta Mercado, filed a claim for death compensation benefits. The Acting Referee of Regional Office No. 4, Department of Labor, Manila, awarded benefits. However, the Workmen's Compensation Commission reversed this award, dismissing the claim for lack of merit. The Petition: The widow filed a petition for review, treating it as a Special Civil Action, challenging the Commission's decision.
Issue(s)
Whether or not the illness of Regalado Mercado which caused his death is compensable under the Workmen's Compensation Act, as amended.
Ruling
The judgment of the Workmen's Compensation Commission is reversed and set aside, and the Acting Referee's decision is reinstated. The respondent employer is ordered to pay death compensation benefits and reimbursement of burial expenses.
Ratio Decidendi
On Issue 1: The Supreme Court held that the illness of Regalado Mercado, which caused his death, is compensable under the Workmen's Compensation Act, as amended. The Court predicated its decision on the legal presumption mandated by Section 44 of the Workmen's Compensation Act (Act No. 3428, as amended), which states that once an illness supervenes during the course of employment, there is a legal presumption that the illness arose out of or was at least aggravated by the employment. The deceased started working in 1963 and was found to be afflicted with "cirrhosis of the liver" in October 1973, ten years into his employment, which gives rise to this presumption. The private respondent's failure to present evidence to rebut this presumption, despite the WCC's speculative assertion of alcohol intake, was critical. The Court emphasized that the burden of proving that the illness was not work-connected or work-aggravated shifted to the employer, which they failed to discharge. Furthermore, the Court reiterated the principle from Abana vs. Quisumbing that it is not required for employment to be the sole factor in the growth, development, or acceleration of the illness or death; it is sufficient that the employment contributed, even in a small degree, to the development of the disease and in bringing about the death. The attending physician's report, stating the illness was "aggravated by his employment due to heavy and too much physical exertion and irregular meals," supported the finding of compensability.
Main Doctrine
Under the Workmen's Compensation Act, once an illness is established to have supervened during the course of employment, there is a legal presumption that it arose out of or was at least aggravated by the employment, shifting the burden of proof to the employer to rebut this presumption.