Abordo v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Francisco Abordo, employed by Philippine National Railways (PNR) as a Switchman Helper, filed a claim for disability benefits alleging he contracted rheumatoid arthritis on November 8, 1972, in the course of his employment. He stopped working on February 11, 1973, upon retiring under Republic Act 660. Attached to his claim was a Physician's Report stating the sickness was diagnosed as rheumatoid arthritis, caused by degenerative changes, aggravated by employment, and resulted in indefinite total disability for labor. Procedural History: The Acting Referee dismissed the claim for lack of merit, noting that Abordo did not fill out the disability column in his retirement application. The Workmen's Compensation Commission affirmed this decision, adding that Abordo retired optionally and that the Commission "failed to see from the record that the herein claimant suffered from any disability for labor at any time during the period of his employment with the respondent." The Petition: This petition seeks to review the decision of the Workmen's Compensation Commission affirming the dismissal of the claim for disability benefits.
Issue(s)
Whether the failure to fill out the disability column in the retirement application bars the claim for disability benefits. Whether the Workmen's Compensation Commission erred in finding that the claimant did not suffer from any disability for labor during his employment.
Ruling
The decision appealed from is set aside. The respondent Philippine National Railways is ordered to pay the petitioner disability compensation benefits, attorney's fees, and administrative fees.
Ratio Decidendi
On the issue of failure to fill out the disability column: The Court held that the petitioner's failure to fill out the disability column in his retirement application is of no moment. The petitioner's reason for retiring under Republic Act 660, which provides for optional retirement, was precisely because he was no longer fit to perform the usual duties demanded by his job with the PNR. This indicates that his retirement was necessitated by his condition, not a voluntary act devoid of any underlying disability. The Court emphasized that the purpose of the retirement was to avail of benefits due to his perceived unfitness for continued service. On the issue of the Commission's finding of no disability: The Court found the Commission's conclusion that the claimant did not suffer from any disability for labor contrary to the evidence presented. The report of Dr. Jose D. Bernas, the PNR's own physician, categorically stated that the claimant's sickness caused temporary total disability for an indefinite period. This report directly contradicted the Commission's finding. The Court highlighted that the physician's report, originating from the employer's physician, served as substantial evidence of the disability. The Court also noted that the sickness supervened during the petitioner's employment with the respondent PNR, triggering the legal presumption under Section 44 of the Workmen's Compensation Act, as amended. This presumption shifts the burden of proof to the employer to demonstrate that the illness did not arise out of or was not aggravated by the employment. The respondent PNR failed to adduce any substantial evidence to disprove the causal connection between the petitioner's rheumatoid arthritis and his employment.
Main Doctrine
The presumption under Section 44 of the Workmen's Compensation Act, as amended, shifts the burden of proof to the employer to disprove the causal connection between the employee's illness and his employment, once it is established that the illness supervened during employment. Failure to fill out a disability column in a retirement application does not negate a claim for disability benefits if the employee retired optionally due to unfitness for work.