Custodio v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Julian Custodio was a seasonal worker for Paniqui Sugar Mills, Inc. for 26 years. He was last employed as an "ashman" and was not rehired for the 1973-1974 milling season after being diagnosed with "Pulmonary Tuberculosis (PTB), minimal" during the company's annual medical examination in August 1973. Procedural History: Petitioner filed a disability compensation claim, which was dismissed along with similar claims from co-workers. The Workmen's Compensation Commission affirmed the dismissal, opining that the PTB was likely contracted during the off-season and was not work-connected. The Commission's opinion was based on probability without supporting evidence. The Petition: Petitioner seeks review of the Commission's decision, arguing that the Commission erred in denying his claim for compensation benefits and that the presumption of compensability under the Workmen's Compensation Act was not overcome by the employer.
Issue(s)
Whether the Workmen's Compensation Commission erred in denying the claim by ruling that the petitioner's Pulmonary Tuberculosis (PTB) was not work-connected, despite the illness supervening during his 26-year employment.
Ruling
The decision of the Workmen's Compensation Commission is REVERSED. The respondent is ordered to pay petitioner disability compensation benefits, medical services, and attorney's fees.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Workmen's Compensation Commission (WCC) erred because it ignored the mandate of Section 44 of the Workmen's Compensation Act, which establishes a presumption of compensability once an illness supervenes in the course of employment. Applying the doctrine from Lorenzo vs. WCC, the Court emphasized that the burden to show by substantial evidence that the illness is not work-related shifts entirely to the employer once supervenience is shown. The WCC's reliance on the 'probability' that the petitioner contracted Pulmonary Tuberculosis (PTB) during the off-season was dismissed as mere conjecture unsupported by evidence, especially since the company failed to conduct medical check-ups at the end of each milling season. The Court reiterated the rule in Vda. de Laron vs. WCC that probability, not certainty, is the touchstone for establishing the link between an injury and employment. Given that Custodio worked for 26 years as an ashman—a job involving heavy manual labor, inhalation of ash dust, and exposure to intense heat—it is medically and legally probable that his PTB was work-induced or aggravated. Therefore, the statutory presumption remained unrebutted, and the petitioner was entitled to disability benefits as a matter of law.
Main Doctrine
The presumption of compensability under Section 44 of the Workmen's Compensation Act shifts the burden to the employer to prove that the illness is not work-connected. Probability, not certainty, is the touchstone in determining the relation between the illness and the employment.