Dizon v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Aurora F. Dizon, a foreign service officer with the Department of Foreign Affairs, filed a claim for compensation due to a psychiatric illness. She alleged that the illness developed in 1964 while she was assigned to the Philippine Mission in Geneva, Switzerland, and was caused by the nature of her employment and aggravated by it. She experienced symptoms of nervousness, irritability, and suspiciousness, leading to her recall to the Philippines for medical treatment. 2. Procedural History: Dizon filed her claim with the Regional Office No. 4 of the Department of Labor, which was docketed as Case No. R04-WC Case No. 153261. A Labor Referee dismissed the case on May 9, 1975, finding that the illness was neither caused by nor aggravated by her employment. Dizon appealed this decision to the Workmen's Compensation Commission, which affirmed the Referee's ruling on November 29, 1975. 3. The Petition: This case is before the Supreme Court on a petition for review of the Workmen's Compensation Commission's decision. Dizon seeks to overturn the Commission's affirmation of the dismissal of her claim. The core of the dispute revolves around whether her psychiatric illness qualifies for compensation under the Workmen's Compensation Act, with the respondents arguing, and the lower bodies agreeing, that the illness was not work-related or aggravated by her employment, despite the presumption of such a connection.
Issue(s)
Whether the petitioner's psychiatric illness is compensable under the Workmen's Compensation Act. Whether the presumption of compensability under Section 44 of the Workmen's Compensation Act was overcome.
Ruling
The decision of the Workmen's Compensation Commission is affirmed. The petitioner is not entitled to compensation.
Ratio Decidendi
On whether the petitioner's psychiatric illness is compensable: The Court affirmed the dismissal of the claim. While Section 44 of the Workmen's Compensation Act creates a presumption that an employee's illness supervening during employment arose out of or was aggravated by said employment, this presumption is rebuttable. In this case, the evidence presented by the petitioner herself, specifically the physician's report from Dr. Baltazar V. Reyes, stated that the illness was psychiatric and could not be the result of the nature of her employment nor was it aggravated by such employment. This report also indicated that the claimant could continue working, which she did. On whether the presumption of compensability was overcome: The presumption of compensability under Section 44 of the Workmen's Compensation Act was overcome by the evidence presented. The physician's report, which was part of the petitioner's own evidence, explicitly stated that the psychiatric illness was not due to nor aggravated by her employment. Furthermore, the petitioner's leaves of absence, as detailed in the records, were for reasons unrelated to her alleged psychiatric ailment, such as vacation, caring for her mother, or mild influenza. The fact that she continued to work with the Department of Foreign Affairs also indicated that she was not disabled by the illness, thereby negating the claim for compensation based on disability arising from employment.
Main Doctrine
The presumption of compensability under Section 44 of the Workmen's Compensation Act is rebuttable. If the claimant's physician explicitly states in the report that the illness is psychiatric and not due to or aggravated by employment, and the claimant is not disabled and continues to work, the claim for compensation may be dismissed.