Olino v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Maria C. Olino, a public school teacher for 44 years, developed bilateral cataracts. Her physician attributed the ailment to factors including lack of vitamins, eye infection, and excessive use of her eyes, noting that her occupation as a teacher could have aggravated the condition. Advised to retire to prevent complete loss of eyesight, she retired from government service on January 2, 1974. Procedural History: Olino filed a claim for compensation in March 1975 for her ailment, allegedly contracted during her employment. The Hearing Officer of Regional Office No. 9 found the claim compensable, ordering the Department of Education and Culture to pay benefits, attorney's fees, and administrative fees. The Office of the Solicitor General, after receiving the decision on September 1, 1975, filed a petition for relief from judgment with the Workmen's Compensation Commission (WCC) on December 4, 1975, ninety-four days later. The WCC set aside the Hearing Officer's decision, dismissing the claim. The Petition: This petition seeks review of the WCC's decision. The petitioner raises three main questions: (1) whether the WCC had jurisdiction to entertain the petition for relief from judgment filed beyond the reglementary period; (2) whether the claimant's evidence sufficiently established her claim in the absence of substantial contrary evidence; and (3) whether cataracts contracted and aggravated during her employment as a public school teacher are compensable. The petitioner argues that the Solicitor General's petition for relief was filed out of time and that her illness is compensable due to aggravation during her employment, supported by medical findings of significant vision loss.
Issue(s)
Whether the Workmen's Compensation Commission has jurisdiction to entertain the petition for relief from judgment filed by the respondent Republic of the Philippines, Department of Education and Culture (Bureau of Public Schools) ninety-four (94) days from receipt of a copy of the decision it seeks to set aside. Whether, in the absence of substantial evidence to the contrary, the evidence presented by claimant during the hearing sufficiently establishes her claim. Whether cataract contracted by claimant during her employment as public school teacher and aggravated by her duties as such, is compensable.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the Department of Education and Culture (Bureau of Public Schools) to pay the petitioner compensation benefits, reimbursement for medical expenses, attorney's fees, and administrative fees.
Ratio Decidendi
On the jurisdiction of the WCC to entertain the petition for relief: The Court held that the petition for relief from judgment was filed out of time. Rule 22 of the Revised (1973) Rules of the Commission mandates that such a petition must be filed within thirty (30) days after the petitioner learns of the decision sought to be set aside and not more than three (3) months after the decision was entered. The Solicitor General's petition, filed ninety-four (94) days after receipt of the decision, was therefore fatal. The contention that the Hearing Officer had no jurisdiction because the claimant was already retired when the claim was filed was also dismissed, as the claim was filed within one year after retirement, and the liability under the Workmen's Compensation Act is a legal obligation enforceable within ten years. The Court cited National Development Company vs. Roberta Rongavilla et al. to support the ten-year prescriptive period for enforcing legal obligations. On the sufficiency of claimant's evidence and compensability of the ailment: The Court found the appeal meritorious, even assuming the decision had not become final. It was established that the claimant's illness, bilateral cataract, supervened during her employment. Her duties as a teacher, which involved reading and writing lesson plans, particularly under insufficient light from a gas lamp due to lack of electricity in the barrio, clearly aggravated her condition. The medical advice for her to retire to prevent complete loss of eyesight underscored the severity and work-related aggravation of her ailment. The Compensation Medical Rating Officer's findings of temporary partial disability and permanent partial/total disability further supported the claim. On the presumption of compensability and burden of proof: Section 44 of the Workmen's Compensation Act establishes a disputable presumption of compensability. Since the illness supervened during employment, the burden was on the employer, the Bureau of Public Schools, to prove by substantial evidence that the illness was not work-connected. The Court noted that the Bureau of Public Schools presented no evidence to controvert the claim. Furthermore, in light of the constitutional mandate to protect labor, such presumptions should be interpreted broadly in favor of the employee. The claimant also adduced competent evidence, not just relying on the presumption, that her illness was aggravated by her work.
Main Doctrine
The illness of a public school teacher, bilateral cataract, which supervened during her employment and was aggravated by her duties, is compensable under the Workmen's Compensation Act. The employer bears the burden of proving by substantial evidence the absence of work connection. A petition for relief from judgment filed beyond the reglementary period is fatal.