Aguilar v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Socorro T. Aguilar, widow of the deceased Antonio Aguilar, filed a claim for death and medical benefits. Antonio Aguilar, a General Education Supervisor for the Bureau of Public Schools, died on November 13, 1974, of "intra-cerebral hemorrhage." He was diagnosed with rheumatoid arthritis and peptic ulcer on April 15, 1974, and retired on optional retirement effective May 1, 1974. A physician's report indicated Antonio Aguilar suffered from "essential hypertension" since 1959, which was allegedly the result of his employment, and incurred P3,224.33 in medical expenses. Procedural History: The claim was dismissed by the Acting Referee of Regional Office No. 7, Department of Labor, Cebu City, for lack of employer-employee relationship at the time of death and because the cause of death was not proven to be employment-related. The Workmen's Compensation Commission affirmed this decision. The Petition: This case is a petition for certiorari to review the decision of the Workmen's Compensation Commission.
Issue(s)
Whether the death of a former employee occurring after optional retirement is compensable under the Workmen's Compensation Act (WCA) if the causative illness supervened during employment. Whether a physician's report (W.C. Form No. 4) is admissible as substantial evidence to support a claim for compensation despite being hearsay under common law rules.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The respondent, Republic of the Philippines (Bureau of Public Schools), is ordered to pay petitioner death compensation, reimbursement for medical expenses, attorney's fees, and administrative fees.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the death is compensable notwithstanding the fact that Antonio Aguilar was no longer an employee of the Bureau of Public Schools (BPS) at the precise time of his death. The Court emphasized that the decedent's death from intra-cerebral hemorrhage was the direct consequence of hypertension, an illness that was documented to have started in 1959 during his employment. Under the Workmen's Compensation Act (WCA), the law presumes that a claim is compensable if the illness supervened during the course of employment, and the burden to disconnect the sickness from employment rests solely on the employer. Since the respondent failed to present any substantial evidence to rebut this finding, the statutory presumption remains undisturbed. The fact that death occurred five and one-half months after retirement is of no moment because the underlying cause was contracted while he was still in the service. On Issue 2: The Court held that a physician's report is admissible and constitutes substantial evidence to support a compensation award. While the respondent objected to the report as hearsay because the doctor was not presented as a witness, the Court clarified that Section 49 of the WCA explicitly allows for the admission of such reports. Applying the precedent in Pioneer Ceramics, Inc. vs. Samia, the Court noted that administrative proceedings are not strictly bound by common law rules of evidence. The physician's report, stating that the hypertension was the result of the nature of the decedent's employment, is sufficient when the employer fails to controvert it. As a piece of social legislation, the WCA must be liberally construed to attain its purpose of providing relief to the workman and his dependents.
Main Doctrine
A physician's report, though hearsay under common law, is admissible under Section 49 of the Workmen's Compensation Act and can be the basis for an award. The law presumes claims are compensable in the absence of substantial evidence to the contrary, and the burden to disconnect the illness from employment rests on the employer.