Martillo v. Republic
REITERATIONFacts
1. The Antecedents: Norberta Martillo, an employee of the National Library for thirty-nine years, retired at age 62. During her service, she underwent gall-bladder and appendectomy operations, and was later hospitalized for cholecystitis with cholelithiasis and myocardial ischemia. She filed a claim for compensation for these illnesses. 2. Procedural History: A Hearing Officer initially awarded Martillo P6,000.00 in compensation and P1,430.82 for medical expenses. The respondent, Republic of the Philippines (National Library), moved for reconsideration, which was denied. The case was elevated to the Workmen's Compensation Commission (WCC), which reversed the award, stating the illnesses were not proven to be contracted during employment and that Martillo had already retired. This petition for review followed. 3. The Petition: Martillo seeks review of the WCC's decision, arguing that her illnesses arose out of and in the course of her employment. The petition contends that the WCC erred in reversing the award, particularly by failing to consider the presumption that illnesses supervening during employment are work-related and by disregarding the medical evidence of her hospitalizations. It also asserts that her retirement at age 62, due to physical incapacitation, entitles her to disability benefits.
Issue(s)
Whether the Workmen's Compensation Commission has jurisdiction over a claim filed after the employee's retirement. Whether the petitioner's illnesses are compensable under the 'presumption of compensability' doctrine. Whether optional retirement at age 62 constitutes evidence of physical incapacity for disability benefits.
Ruling
The Supreme Court set aside the decision of the respondent Commission and reinstated the award made by the Hearing Officer in favor of the petitioner. The employer, Republic of the Philippines (National Library), was ordered to pay the petitioner P6,000.00 as compensation, P61.00 as administrative fee, P600.00 as attorney's fees, and P1,430.82 for reimbursement of medical expenses.
Ratio Decidendi
On Issue 1: The Court ruled that the failure of an employee to comply with the notice and claim requirements of Section 24 of Act No. 3428 is non-jurisdictional. Delay in filing is not a bar to compensation if the employer had knowledge of the illness or suffered no prejudice. Furthermore, the duty of an employer to provide medical attendance subsists even after separation from service, as long as the illness was incurred during employment and medical services are required for relief. Citing Centino v. WCC, the Court emphasized that separation from the service does not extinguish the right to compensation for work-related ailments. On Issue 2: The Court applied the 'Presumption of Compensability.' It was undisputed that Martillo's illnesses—Cholecystitis and Myocardial Ischemia—supervened in 1972 while she was still a provincial librarian. Once supervenience is established, the law presumes the illness arose out of or was aggravated by the employment. The burden then shifted to the National Library to rebut this presumption with substantial evidence. Since the employer failed to appear at the hearing or provide rebuttal evidence, the presumption remains unrebutted and the claim is compensable. On Issue 3: The Court held that Martillo's optional retirement at age 62, as opposed to the compulsory age of 65, is a significant indicator of disability. Under Memorandum Circular No. 133, optional retirement is only recommended for approval if the employee is 'physically incapacitated to render further efficient service.' Therefore, the approval of her retirement application by the government is an admission that she was physically incapacitated. This incapacity, occurring during her service, entitles her to the disability benefits provided under the Workmen's Compensation Act as held in Guevarra v. Republic.
Main Doctrine
The presumption of compensability arises when an illness supervened during employment, and the burden to overthrow this presumption rests with the employer. The fact that a claim is filed after retirement does not divest the Workmen's Compensation Commission of its jurisdiction, nor does it affect the employer's duty to provide medical attendance for a compensable illness incurred during employment.