Villegas v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Maria V. Villegas is the widow of Vicente Villegas, a Division Superintendent of Public Schools for Eastern Samar who served for over thirty years. His position required extensive travel. In 1967, he suffered bodily weakness and general debility but continued working. On February 21, 1970, while supervising the construction of a Boy Scouts Jamboree Camp, he experienced severe vomiting and loose bowel movement. Despite his condition, he continued working to ensure the project's completion. On March 24, 1970, he was diagnosed with Adenocarcinoma of the Rectum, diabetes mellitus, and hypertension. He filed a sick leave and retired on May 14, 1970. He underwent biopsy and surgery, but developed complications leading to Uremia. He died on November 19, 1970, with the death certificate stating "Uremia metastatic carcinoma of the rectum" as the cause. Procedural History: Petitioner filed a claim for death compensation benefits and medical expenses. The Hearing Referee awarded P4,680.00 as compensation, P200.00 for burial, and P9,468.30 for medical expenses. The employer, Republic of the Philippines (Bureau of Public Schools), through the Assistant Provincial Fiscal, endorsed the decision favorably, admitting compensability. An amended decision increased medical expenses to P20,771.10. The employer moved for reconsideration, questioning the reasonableness of the medical expenses. The Hearing Referee explained the amount was based on evaluated receipts. The employer requested re-evaluation, but the Evaluation Division returned it, stating it could only act upon appeal. The employer then filed a motion for extension to file a motion for reconsideration and later a petition to elevate the records, still questioning the medical expenses. On February 27, 1976, the Workmen's Compensation Commission reversed the Hearing Referee's award, ruling the illness non-compensable and denying all claims. The Petition: Petitioner filed a petition for review, alleging grave abuse of discretion by the respondent Commission for exceeding its authority by deciding on compensability, which had become final, and for disregarding the statutory presumption of compensability and established jurisprudence, particularly in cancer cases.
Issue(s)
Whether the Workmen's Compensation Commission gravely abused its discretion in reversing the Hearing Referee's decision on the issue of compensability, which had already become final and was admitted by the employer. Whether the illness of the deceased Vicente Villegas was compensable under Act 3428, considering the presumption of compensability and the fact that the illness supervened during the course of employment. Whether the amount awarded for medical expenses was reasonable and properly substantiated.
Ruling
The decision of the Workmen's Compensation Commission is reversed and set aside. The original award made by the Hearing Referee is reinstated, granting petitioner P4,680.00 as compensation benefits, P200.00 as burial expenses, P9,463.30 as medical expenses, P234.00 as attorney's fees, and P47.00 as administrative fee.
Ratio Decidendi
On the issue of grave abuse of discretion and finality of the Hearing Referee's decision: The respondent Commission exceeded its authority by ruling on the compensability of the illness, which had already become final and settled. This was evident because the employer did not appeal the compensability issue but only questioned the amount of medical expenses. Furthermore, the employer's representative had endorsed the Hearing Referee's decision favorably, admitting the compensability of the claim. The employer's subsequent actions focused solely on the reasonableness of the medical reimbursement, not on whether the illness itself was work-related. Therefore, the Commission's reversal on grounds of non-compensability constituted a grave abuse of discretion, as it disregarded the finality of the prior ruling and the employer's admission. On the compensability of the illness: Even if the issue of compensability were to be considered, the ruling would still favor the petitioner. The Court has consistently held that once an illness supervenes during the course of employment, the presumption of compensability under Section 44 of Act 3428 applies, unless rebutted by substantial evidence. This presumption shifts the burden to the employer to prove that the illness is not work-connected or work-aggravated. In this case, the employer did not present evidence to rebut the presumption; instead, they admitted compensability. The deceased's extensive travel and demanding work duties, coupled with the onset of his illness during his employment, support the conclusion that the illness was either work-connected or work-aggravated. On the amount of medical expenses: The Court found the increase in medical expenses from P9,463.30 to P20,771.10 unwarranted. The request for re-evaluation by the Evaluation Division was returned on the ground that it could not pass upon the reasonableness of the claim unless the case was appealed to the Commission. Given this procedural issue and the fact that the original award was based on properly evaluated documentary evidence, the Court ruled that the original amount of P9,463.30 awarded by the Hearing Officer should stand.
Main Doctrine
The Workmen's Compensation Commission committed grave abuse of discretion when it reversed the Hearing Referee's award by ruling that the deceased's illness was non-compensable, especially when the employer had admitted compensability and did not contest it, and when the illness supervened during the course of employment, thus falling under the presumption of compensability under Act 3428.