Flores v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Salvador Flores, employed by Pantranco South Express, Inc. since 1952 in various capacities including driver, dispatcher, and line inspector, fell ill in 1970 with cardio respiratory arrest, myocardial infarction, bronchial asthma, and acute broncho-pneumonia. Although he returned to work intermittently, his employment was terminated on September 30, 1972. His ailments recurred on July 7, 1974, leading to his death on July 20, 1974. His widow, Dulce Vda. de Flores, filed a claim for death benefits for herself and their minor children. Procedural History: The Acting Labor Referee initially awarded death benefits, burial expenses, and medical expenses to the petitioners. Respondent Pantranco's motion for reconsideration was denied, and the case was elevated to the Workmen's Compensation Commission. The Commission reversed the award, finding that the petitioner failed to establish a causal connection between the deceased's employment and his ailments and subsequent death. The petitioners then sought review of this decision. The Petition: This case is before the Supreme Court on a petition for review of the Workmen's Compensation Commission's decision. The petitioners argue that the Commission erred in reversing the Acting Labor Referee's award. They contend that the presumption of compensability for illnesses that supervene during employment, coupled with the employer's failure to controvert the claim, should have led to an award. Furthermore, they assert that the two-year period for filing a claim should be counted from the date of disability, not merely from the contraction of the illness, as the deceased was terminated due to his health condition and died within two years of that termination.
Issue(s)
Whether the death of Salvador Flores is compensable despite occurring four years after the initial contraction of the illness in 1970. Whether the failure of the employer to formally controvert the claim and formally offer evidence affects the compensability of the death. Whether the two-year period under Section 8 of the Workmen's Compensation Act should be reckoned from the medical contraction of the disease or the date of actual physical disability.
Ruling
The Supreme Court reversed and set aside the decision of the Workmen's Compensation Commission and reinstated the award made by the Acting Labor Referee. No pronouncement as to costs.
Ratio Decidendi
On Issue 1: The Court applied the well-settled rule that once an ailment supervenes in the course of employment, there exists a rebuttable presumption that it arose out of or was at least aggravated by such employment. Applying 'Talip vs. WCC,' the burden to overthrow such presumption shifts to the employer, relieving the claimant from the burden of showing causation. In this case, PANTRANCO failed to discharge this burden and did not even bother to controvert the claim. The absence of controversion constitutes a constructive admission of the compensability of the claim and is fatal to any defense the employer may interpose. The Court emphasized that it is sufficient to show the hypothesis of work-connection is probable, rather than proving it to the point of demonstration. On Issue 2: The Court ruled that PANTRANCO's failure to formally submit evidence within the period granted by the Referee meant that the documents attached to the motion for reconsideration had no evidentiary value. Counsel for PANTRANCO waived the presentation of evidence during the hearing and later failed to submit written affidavits within the five-day extension granted by the Referee. The Court held that for all legal intents and purposes, no evidence was presented by the employer to rebut the claim. The judiciary must consider the case strictly in accordance with the evidence formally submitted and admitted during the hearing. Consequently, the employer's defenses regarding separation pay and the nature of the illness were not legally established. On Issue 3: Regarding the prescriptive period in Section 8 of the Workmen's Compensation Act (WCA), the Court reaffirmed the doctrine in 'Central Azucarera Don Pedro vs. De Leon.' This doctrine holds that the two-year period for death claims should be counted from the date the disease or illness renders the employee physically disabled to do work, rather than a literal interpretation of the date the sickness was contracted. Since Flores was separated from service due to ill-health on September 30, 1972, that date is considered the commencement of his physical disability. As he died on July 20, 1974, his death occurred within the two-year period from the time he became disabled. Thus, the claim for death benefits was timely and valid under the social justice intent of the law.
Main Doctrine
Once an ailment supervened in the course of employment, there is a rebuttable presumption that it arose out of or was aggravated by such employment, shifting the burden to the employer to disprove it. The precise medical cause of the illness is not legally significant if it supervened during employment. Furthermore, the two-year period for filing a claim for death benefits should be counted from the date the employee's sickness rendered him physically disabled to work, not merely from the date the sickness was contracted.