Marapo v. Philippine Packing Corporation
REITERATIONFacts
The Antecedents: Eliseo Marapo, employed as a Security Guard by Philippine Packing Corporation for approximately 16 years and 10 months, fell ill on April 4, 1971, complaining of an illness that led to his confinement and subsequent death on April 20, 1971, after being diagnosed with amoebic liver abscess. He was survived by his wife, Eunila Marapo, and their nine minor children. Procedural History: The petitioners, Eunila Marapo and her minor children, filed a claim for death compensation benefits with the Workmen's Compensation Unit, Regional Office No. XI. The Referee dismissed the claim, holding that amoebic liver abscess was neither an occupational disease nor aggravated by the deceased's employment. This decision was affirmed by the Workmen's Compensation Commission. The petitioners appealed this affirmation. The Petition: This case is a petition for review, treated as a special civil action, challenging the Workmen's Compensation Commission's decision. The petitioners argue that the illness arose out of or was at least aggravated by the deceased's employment, invoking the legal presumption of compensability established in previous cases. They contend that the illness supervened during employment, relieving them of the burden to prove causation. The respondents, however, maintain that they have presented substantial evidence to rebut this presumption.
Issue(s)
Whether amoebic liver abscess is a compensable illness per se under the Workmen's Compensation Act. Whether the illness that caused the death of Eliseo Marapo arose out of or was aggravated by the nature of his employment. Whether the respondent corporation presented substantial evidence to overcome the presumption of compensability.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Commission, ordering the respondent corporation to pay the petitioners P6,000.00 as death compensation benefits and P200.00 as burial expenses.
Ratio Decidendi
On the issue of whether amoebic liver abscess is a compensable illness per se: The Court noted that the respondent Commission affirmed the Referee's holding that amoebic liver abscess is not an occupational disease and therefore not compensable per se. However, the core of the petition revolved around the presumption of compensability when an illness arises during the course of employment, rather than whether the illness itself was an occupational disease. On the issue of whether the illness arose out of or was aggravated by the nature of employment: The Court reiterated the established legal presumption that once an illness supervened during the time of employment, there is a rebuttable presumption that such illness is out of employment or was at least aggravated by such employment. The claimant is relieved from the burden of proving causation. The Court found that the deceased acquired the illness while living in the area provided by the respondent corporation for its employees and during the course of his employment. The Court also considered the poor sanitary condition of the toilet system near the water source, suggesting a potential for contamination that could lead to such illness, even if the water source itself was periodically found to be potable. The Court emphasized that the illness could have come from contaminated food as well, given the exposed living area. On the issue of whether substantial evidence was presented to overcome the presumption: The Court found that the respondent corporation failed to adduce substantial evidence to overcome the presumption of compensability. While the respondent presented evidence regarding the water source, the Court pointed out that the proximity of the faucet to open toilet bowls and the possibility of contamination from food sources were not adequately addressed. The fact that the deceased acquired the illness while living in the area provided by the respondent corporation and during his employment was sufficient to uphold the legal presumption mandated by Section 44 of the Workmen's Compensation Act in favor of the deceased.
Main Doctrine
Once an illness supervened during the course of employment, there is a rebuttable presumption that it arose out of or was aggravated by such employment, relieving the claimant from the burden of proving causation. The employer must present substantial evidence to overcome this presumption.