Gomez v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Trinidad Gomez was employed by the Bureau of Public Schools as a classroom teacher, later promoted to head teacher and Principal I. She stopped working on May 23, 1973, due to physical disability from coronary insufficiency, error of refraction, and hypertension, ailments she experienced starting in 1971. Her physician advised her to stop working and rest. Consequently, she applied for and was approved for optional retirement by the Government Service System. Procedural History: A decision was rendered by the Acting Referee of the Workmen's Compensation Section, Regional Office No. 4, on October 30, 1975, ordering the Bureau of Public Schools to pay petitioner P6,000.00 as disability compensation benefits and P61.00 as decision fees. The Office of the Solicitor General filed a Petition for Relief from Judgment on February 27, 1976, citing work pressure as the reason for failing to file a motion for reconsideration within the reglementary period. The respondent Commission, on March 4, 1976, reversed the Acting Referee's decision and denied the claim, finding the illness not compensable and that petitioner voluntarily retired at age 63, not disabled by illness during employment. The Petition: Petitioner sought a review of the Commission's decision, raising two issues: (1) grave abuse of discretion in reopening the case, and (2) excess of jurisdiction in denying her claim.
Issue(s)
Whether the Workmen's Compensation Commission committed a reversible error amounting to grave abuse of discretion in reopening the case. Whether the Workmen's Compensation Commission committed a reversible error amounting to an excess of jurisdiction in denying the compensability of petitioner's claim.
Ruling
The judgment of the respondent Commission is reversed and set aside. The Republic (Bureau of Public Schools) is ordered to pay petitioner P6,000.00 as disability compensation benefits, reimburse her medical and hospital expenses supported by receipts, pay her lawyer P600.00 as attorney's fees, and pay P61.00 as administrative fees.
Ratio Decidendi
On the issue of reopening the case: The Court found that the Office of the Solicitor General's Petition for Relief from Judgment was filed beyond the reglementary period. The excuse of work pressure was deemed insufficient. The decision of the Acting Referee had become final and executory, divesting the respondent Commission of its appellate jurisdiction to review the decision. Therefore, the reopening of the case constituted grave abuse of discretion. On the issue of compensability: Even assuming the Commission had the power to review, the Court found the petition meritorious. It was established that petitioner suffered from coronary insufficiency, error of refraction, and hypertension, which constrained her to retire. These illnesses supervened during her employment. The Court reiterated the well-settled rule that when an illness supervenes during 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 respondent failed to present evidence to overcome this presumption. Furthermore, the respondent failed to file an answer or notice of controversion, which is fatal to any defense and is deemed an admission that the claim is compensable. The approval of her optional retirement at age 63, given the circumstances, indicated physical incapacity to render efficient service, aligning with the conditions for retirement approval under the relevant circular.
Main Doctrine
Failure of the employer to controvert the claim for compensation benefits within the reglementary period is fatal to any defense, including non-compensability of the illness, and is deemed an admission that the claim is compensable. Furthermore, the approval of an optional retirement application at age 63, under the relevant circular, implies that the employee was physically incapacitated to render further efficient service.