Galler v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Eustaquio Galler, an employee of the Philippine Packing Corporation for 17 years, worked as a field worker performing manual labor exposed to the elements. Weeks before his death on May 17, 1967, he began complaining of chest, back, and nape pains. He died leaving a widow and five minor children. Procedural History: The widow and children filed a claim for compensation benefits for Eustaquio Galler's death, which the Philippine Packing Corporation controverted. The Acting Referee ruled in favor of the claimants, awarding death benefits and burial expenses. However, the Workmen's Compensation Commission reversed this decision, absolving the respondent corporation of liability. The Commission reasoned that the pains were likely due to muscle fatigue and not indicative of a compensable ailment, and that death during sleep, away from work, could not be presumed to be work-related. The Petition: This case comes before the Supreme Court as a petition for review of the Workmen's Compensation Commission's decision. The petitioner argues that the deceased's prolonged exposure to the elements and the onset of specific pains months before his death, despite 17 years of similar work, suggest an illness aggravated or caused by his employment. The petition contends that the employer failed to overcome the legal presumption that an illness supervening during employment is work-related and that the Commission erred in its interpretation of the evidence and the law regarding compensability.
Issue(s)
Whether the illness that caused the death of Eustaquio Galler is compensable under the Workmen's Compensation Act. Whether the respondent Philippine Packing Corporation discharged its burden of proof to overcome the presumption of compensability. Whether the death compensation awarded by the referee was in accordance with the law.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Commission, ordering the private respondent to pay the petitioner and her five minor children P6,000.00 as death compensation benefits, reimburse medical and hospital expenses, pay P200.00 for burial expenses, P600.00 as attorney's fees, and P61.00 as administrative fees.
Ratio Decidendi
On the compensability of the illness and the employer's burden of proof: The Court held that the employer bears the burden of disproving by substantial evidence the strong presumption that an illness which supervened during employment arose out of or was aggravated by it. The WCC's conclusion that the pains were merely muscle fatigue was unsubstantiated, especially since the deceased had been performing the same work for 17 years without prior complaints of such pains until a few months before his death. The Court emphasized that the mere opinion of doctors presented by the employer cannot prevail over the legal presumption of compensability. The Court cited the liberal attitude in upholding this presumption, noting that when an employee satisfies human wants during employment, any resulting harm or death is considered occurring in the course of employment unless clearly shown otherwise. The respondent failed to present substantial evidence to overcome this presumption. On the cause of death and the presumption of compensability: The Court found that the cause of death, certified as "Bangungot," was not conclusive as no autopsy was conducted. Dr. Sison's testimony suggested the possibility of heart failure or heart attack, which could have developed during the last few months of employment. The Court reiterated that the presumption of compensability applies when an illness supervenes during employment, and the employer must prove otherwise. The fact that the deceased complained of pains in his chest, back, and nape for months before his death, and that these pains were not present during the earlier years of his employment, indicated a possible link between the illness and his work, which exposed him to the elements. The Court found no clear showing that the mishap occurred outside the course of employment. On the award of death compensation: The Court noted that the death compensation awarded by the referee was not in accordance with Section 8 of the Workmen's Compensation Act. The deceased, survived by a widow and five minor children, was entitled to the full death compensation of P6,000.00, with 60% for the widow and 40% for the children. The Court also affirmed the P200.00 burial expenses, attorney's fees, and administrative fees as provided by law.
Main Doctrine
The employer bears the burden of disproving by substantial evidence the strong presumption that an illness which supervened during employment arose out of the employment or was at least aggravated by it. The mere opinion of doctors presented by the employer that would disconnect the deceased employee's death from his employment cannot prevail over the presumption established by law.