Randoy v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for death compensation benefits filed by Rosalia Vda. de Randoy, the widow of Bonifacio Randoy, a painter employed by Universal Textile Mills, Inc. Bonifacio Randoy died in his sleep on December 13, 1974, with the cause of death listed as congestive heart failure. The employer controverted the claim, asserting that the death was not service-connected. 2. Procedural History: Rosalia Vda. de Randoy initially filed an application for separation pay on January 8, 1975, and subsequently filed a notice and claim for compensation on March 19, 1975. The claim was dismissed by the Acting Referee of Regional Office No. 4, Department of Labor, for failure to establish a causal relation between the death and the employment, as no death certificate or physician's report was initially presented. A motion for reconsideration with the death certificate attached was denied. The Workmen's Compensation Commission affirmed the referee's decision, holding that the death did not arise out of or in the course of employment and that there was no evidence of prior heart complaints related to his work. 3. The Petition: This case comes before the Supreme Court on a petition for review of the Workmen's Compensation Commission's decision. The petitioner argues that the Commission erred in dismissing the claim, contending that under established jurisprudence, particularly Talip vs. Workmen's Compensation Commission, an illness that supervenes during employment is presumed to be work-related or aggravated, shifting the burden of proof to the employer to disprove causation. The petitioner asserts that the employer failed to discharge this burden, and therefore, the death should be considered compensable.
Issue(s)
Whether the death of Bonifacio Randoy due to congestive heart failure is compensable under the Workmen's Compensation Act. Whether the presumption of compensability applies in this case.
Ruling
The decision of the respondent Commission is set aside. Universal Textile Mills, Inc. is ordered to pay the petitioner death compensation benefit, burial expenses, attorney's fees, and administration fee.
Ratio Decidendi
On the compensability of death due to congestive heart failure: The Court reiterated the well-settled jurisprudence that once it is established that an illness supervened during employment, there is a rebuttable presumption that such illness arose out of the employment or was at least aggravated by it. The employer has the burden of proving the contrary by substantial evidence. In this case, the death certificate stated congestive heart failure as the cause of death, and the deceased died while in the employ of the respondent. The finding that there was no prior complaint referable to the heart strengthens the presumption that the fatal heart attack was work-connected or aggravated. On the presumption of compensability: The Court emphasized that Section 44 of the Workmen's Compensation Act mandates a presumption that an employee's illness which supervened during employment arose out of, or was aggravated by, the employment. This presumption shifts the burden of proof to the employer to disprove the claim by substantial evidence. The respondent employer failed to discharge this burden. The Commission's conclusion that there was a want of a preliminary link between the deceased's work and his death was contrary to this legal presumption. The absence of a history of cardiac ailments, as noted by the Commission, further strengthens the presumption that the fatal heart attack was work-connected or aggravated and therefore compensable.
Main Doctrine
The death of an employee due to illness, even if not occupational, is presumed to have arisen out of or at least was aggravated by his employment, and the employer bears the burden of proving otherwise by substantial evidence. The employer failed to discharge this burden.