Marquez v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Gregoria Marquez filed a claim for compensation for her illness, "Resoma Uteri Cystic Ovary, Bilateral," which allegedly supervened during her employment as a classroom teacher for the Bureau of Public Schools. She was employed at Rizal Elementary School, Bacolod City, and was a permanent employee receiving a monthly salary of P349.00, working at least five days a week. The illness required medical treatment for forty-five (45) days, during which she could not render service. She was operated on due to her illness and was reinstated to her position after recovery. Marquez attributed her illness to the nature of her work, citing exposure to heat, rain, and inclement weather, and the necessity of standing for hours without being able to leave her classroom. Procedural History: The Acting Referee of the Workmen's Compensation Unit granted Marquez compensation for temporary total disability for labor for forty-five (45) days. The Bureau of Public Schools appealed to the Workmen's Compensation Commission, which reversed the Acting Referee's decision and absolved the Bureau of Public Schools from liability. The Petition: This case is a petition to review the decision of the Workmen's Compensation Commission.
Issue(s)
Whether the illness of the claimant, Gregoria Marquez, was caused or aggravated by her employment as a classroom teacher. Whether the respondent, Bureau of Public Schools, is liable for compensation for temporary total disability and reimbursement of medical expenses.
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 the petitioner compensation for temporary total disability for labor for forty-five (45) days in the amount of P310.63, to reimburse the petitioner of medical expenses if supported by proper receipts, and to pay the successor of the Workmen's Compensation Commission P5.00 as administrative fees.
Ratio Decidendi
On the issue of whether the illness was caused or aggravated by employment: The claimant's illness, "Resoma Uteri Cystic Ovary, Bilateral," supervened during her employment as a classroom teacher. Under the Workmen's Compensation Act, there is a disputable presumption that an illness supervening during employment is caused or aggravated by said employment. The claimant adduced evidence that her illness was either caused or aggravated by the nature of her work, citing exposure to adverse weather conditions and the demands of her teaching duties. The respondent, Bureau of Public Schools, failed to present any evidence to rebut this presumption or to show that the illness was neither caused nor aggravated by the claimant's work. Therefore, the presumption stands, and the illness is deemed to be work-related. On the issue of liability for compensation and medical expenses: Since the illness was presumed to be work-related and the respondent failed to present evidence to the contrary, the claimant is entitled to compensation for temporary total disability for labor for the period she was unable to work. The Acting Referee correctly granted compensation for forty-five (45) days. Furthermore, the claimant is entitled to reimbursement of her medical expenses, provided they are supported by proper receipts, as these expenses were incurred due to the work-related illness. The respondent is also liable for administrative fees as mandated by the Act.
Main Doctrine
An illness that supervened during employment is presumed to have been caused or aggravated by such employment, unless the employer presents evidence to the contrary. The claimant is entitled to compensation for temporary total disability and reimbursement of medical expenses.