De Vera v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Luis de Vera was employed as a driver by International Container Corporation from November 1970 until June 3, 1972. He filed a claim for disability compensation, alleging that he became sick with peptic ulcer in the course of his employment, which compelled him to cease working. Procedural History: The employer controverted the claim, asserting the ailment was not work-connected. An acting referee initially rendered an award in favor of the claimant. However, upon motion for reconsideration by the employer, the Workmen's Compensation Commission reversed this decision, setting aside the award and dismissing the claim for lack of merit. The Commission reasoned that the claimant failed to prove his illness was causally related to his work and had incapacitated him. The Petition: This case is before the Supreme Court on petition for review of the Workmen's Compensation Commission's decision. The petitioner argues that the Commission erred in reversing the acting referee's award, contending that the Court's established jurisprudence presumes compensability for illnesses that supervene during employment and are aggravated by it, shifting the burden of proof to the employer. The petitioner asserts that the employer failed to provide substantial evidence to overcome this presumption.
Issue(s)
Whether the illness (peptic ulcer) which supervened during De Vera's employment is compensable under the legal presumption established by the Workmen's Compensation Act.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and affirmed the award rendered by the acting referee. The respondent employer was ordered to pay disability compensation, refund medical expenses, provide necessary medical services and supplies, and pay administrative fees.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Workmen's Compensation Commission's decision was contrary to established jurisprudence regarding the legal presumption of compensability. Applying the ruling in Belmonte vs. Workmen's Compensation Commission, the Court emphasized that under Section 44 of the Workmen's Compensation Act, if an illness supervenes at the time of employment, it is presumed to have arisen out of or been aggravated by said employment. This legal presumption shifts the burden of proof to the employer, and the employee is relieved of the burden to show a causal connection. The Court noted that as a driver, De Vera suffered abdominal pains during his employment, which necessitated his resignation and subsequent medical treatment. While the employer suggested that the ulcer could have been caused by 'excessive alcoholic intake' or 'irregular eating habits,' the record was bereft of evidence to substantiate these claims. Following Abana vs. Quisumbing, the Court ruled that even if other factors contributed to the illness, it is enough that the employment contributed 'even in a small degree' to the development of the disease. Finally, the Court clarified that harm to the physical structure of the body need not be external or visible to be compensable, thus affirming the referee's original award.
Main Doctrine
Under the Workmen's Compensation Act, illness supervening during employment is presumed to have arisen out of or been aggravated by such employment, shifting the burden of proof to the employer to disprove the causal connection. The employment need only contribute in a small degree to the development of the illness for it to be compensable.