Bachiller v. Republic
REITERATIONFacts
The Antecedents: Ricardo Bachiller, Sr., a 64-year-old clerk, filed a claim for disability compensation due to Rheumatoid Arthritis and chest pains, which he claimed permanently disabled him from work starting June 1, 1974. He had been suffering from these ailments since January 5, 1973, necessitating intermittent sick leaves. He submitted documentary evidence including his service record, medical history, a statement of duties, leaves of absence, and expenses for medicines and professional fees. Procedural History: The Acting Referee of Regional Office No. 6, Department of Labor, granted an award for disability compensation and reimbursement of medical expenses. However, the Workmen's Compensation Commission (WCC) set aside this award on appeal, holding that rheumatoid arthritis is not a compensable illness as it is a degenerative change due to aging, and thus disallowed the claim for medical expenses. The Petition: Ricardo Bachiller, Sr. sought a review of the WCC's decision, arguing that his illnesses were compensable and that the WCC erred in disallowing his claim.
Issue(s)
Whether rheumatoid arthritis and chest pains, contracted in the course of employment, are compensable illnesses under the Workmen's Compensation Act. Whether the claimant's advanced age and optional retirement preclude him from receiving disability compensation. Whether the claim for medical expenses is valid.
Ruling
The Supreme Court set aside the decision of the respondent Commission and reinstated the Acting Referee's award in favor of the petitioner-claimant. The Court further directed the respondent Bureau of Public Schools to furnish the petitioner with necessary services, appliances, and supplies for his recovery.
Ratio Decidendi
On the compensability of rheumatoid arthritis and chest pains: The Court reiterated its ruling in Buenaflor, et al., vs. Workmen's Compensation Commission & Olaguer that rheumatism, which can result in permanent incapacity, can be due to unusual strain from employment. The Municipal Health Officer certified that Bachiller's chest pains and arthritis were caused by his exposure to heat and cold while mailing and receiving communications and assisting the supply officer. The Court emphasized that under Section 44 of the Workmen's Compensation Act, there is a presumption of compensability for claims occurring in the course of employment and aggravated by duties. The Court cited numerous cases supporting this presumption. It was further clarified that it is not required for employment to be the sole factor in the illness's development; it is sufficient that employment contributed, even in a small degree, to the aggravation of the disease. The Court cited Abana vs. Quisumbing and Bautista vs. WCC, et al. to support this principle. On the effect of advanced age and optional retirement: The Court held that the mere fact that other factors, such as advancing age, may have contributed to the aggravation of the petitioner's illness does not diminish its compensability. Regarding optional retirement, the Court has consistently ruled that an employee's application for optional retirement before reaching the compulsory retirement age is a clear indication of physical incapacity to render efficient service. This ruling is based on Memorandum Circular No. 133 of the Office of the President, which authorizes optional retirement before the compulsory age only when the employee is physically incapacitated to render sound and efficient service. The Court cited Romero vs. WCC, et al. and Ybañez vs. WCC, et al. to support this point. On the claim for medical expenses: Since the Court found the illness to be compensable, the claim for medical expenses, which was certified as fair and reasonable by the Compensation Rating Medical Officer, was also deemed valid and reinstated along with the disability compensation award.
Main Doctrine
An illness contracted in the course of employment, even if aggravated by other factors like age, is compensable under the Workmen's Compensation Act. The employer's failure to properly controvert the claim further justifies an award.