Rabanes v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Justiniano Ortiz, Assistant Provincial Assessor of Misamis Oriental, died on June 29, 1972, from advanced diabetes mellitus with complications. His minor daughter, Irma Ortiz, through her guardian Enrila Ortiz Rabanes, filed a claim for death compensation, alleging that her father's illness occurred and was aggravated in the course of his employment. Procedural History: An Evaluation Committee recommended denial of compensation, stating diabetes mellitus is not an occupational disease but familial and hereditary. However, Referee Rodolfo S. Milado rendered a decision in favor of the heir, awarding compensation. The Provincial Attorney filed a motion for reconsideration, which was denied, and the case was elevated to the Workmen's Compensation Commission (WCC). The WCC reversed the referee's award, agreeing with the Evaluation Committee that diabetes mellitus is familial and hereditary and not work-connected. The Petition: The guardian of Irma Ortiz filed a petition before the Supreme Court, seeking to set aside the decision of the WCC.
Issue(s)
Whether the death of Justiniano Ortiz due to diabetes mellitus is compensable under the Workmen's Compensation Act. Whether the presumption of compensability under Section 44 of the Workmen's Compensation Act was sufficiently overcome by the respondent.
Ruling
The Supreme Court set aside the decision of the respondent Province of Misamis Oriental is ordered to pay Irma Ortiz death compensation, reimbursement of medical and hospital expenses, and burial expenses; to pay claimant's counsel attorney's fees; and to pay the Workmen's Compensation Fund an administrative fee.
Ratio Decidendi
On Whether the death of Justiniano Ortiz due to diabetes mellitus is compensable under the Workmen's Compensation Act: The Court held that the claim is compensable. It reiterated the well-entrenched jurisprudence that where an illness of an employee occurs in the course of employment, it is presumed under the law that such illness was directly caused by or arose out of the employment or was aggravated by it. The fact that diabetes mellitus is considered familial and hereditary does not automatically disconnect it from the employment. The Court emphasized that the medical opinions presented by the employer or the WCC's medical rating officer were insufficient to overthrow this legal presumption. The documentary evidence showed that in the course of his work, Justiniano Ortiz became afflicted with diabetes mellitus, sustained a non-healing wound, and suffered kidney complications, which forced him to take sick leaves and eventually apply for optional retirement. These ailments, coupled with the nature of his work which involved travel and exposure, contributed to the aggravation of his condition. On Whether the presumption of compensability under Section 44 of the Workmen's Compensation Act was sufficiently overcome by the respondent: The Court ruled that the presumption was not overcome. The respondent's argument that the cause of death was not work-connected or work-aggravated but a familial and hereditary disease was found to ignore established jurisprudence. The Court cited previous cases, such as Naira vs. Workmen's Compensation Commission and Vda. de Forteza vs. Workmen's Compensation Commission, which established that in the absence of proof that the injury or death supervening in the course of employment has arisen because of the nature of the same, the death or injury is by law compensable unless the employer clearly establishes that it was not caused or aggravated by such employment or work. In this case, the medical opinions presented by the respondent were insufficient to rebut the presumption, especially in light of Dr. Jose D. Lastimosa's report attesting that the ailments were caused and aggravated in the course of employment. The Court found that the employment had contributed to the aggravation or acceleration of the ailment.
Main Doctrine
Where an illness of an employee occurs in the course of employment, it is presumed under the law that such illness was directly caused by or arose out of the employment or was aggravated by it, and medical opinions disconnecting the ailment from employment are insufficient to overthrow this presumption unless the employer clearly establishes the contrary.