Sebastian v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Sancho Sebastian, employed as a property clerk with a monthly salary of P240.00, filed for sick leave with pay from May 16 to May 31, 1973. He subsequently went on leave with pay from June 1 to June 30, 1973, and was paid for 201 days of vacation and sick leave from July 1, 1973, to January 17, 1974. On May 15, 1973, Sebastian suffered from hypertension and asteriosclorotic heart disease, which a Physician's Report indicated were caused by his employment. Due to these illnesses, he retired at the age of 62 on January 18, 1974. Procedural History: Sebastian filed a claim for compensation on February 3, 1975, asserting his illnesses were work-connected. The Unit's Medical Rating Officer found him to have a permanent partial disability of 25% N.S.D. The Acting Chief of the Workmen's Compensation Unit awarded compensation benefits. The Provincial Government of Sulu (Provincial Waterworks) appealed to the Workmen's Compensation Commission (WCC). The Petition: The WCC reversed the Unit's decision, absolving the Province of Sulu of liability. The WCC found that while the physician's report indicated the illness resulted from the job, there was no substantial evidence presented by the claimant to link his sickness to his work as a property clerk, nor did he explain how the job was conducive to the disease. This petition seeks to review the WCC's decision.
Issue(s)
Whether the illnesses of hypertension and asteriosclorotic heart disease suffered by the claimant are compensable. Whether the employer-employee relationship is suspended when an employee is on leave of absence with pay. Whether the presumption of compensability applies in this case.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The respondent, Provincial Government of Sulu (Provincial Waterworks), is ordered to pay the petitioner P4,249.28 for disability benefits, reimburse medical expenses supported by receipts, pay attorney's fees of P425.00, and pay administrative fees of P61.00.
Ratio Decidendi
On whether the illnesses are compensable: The Court held that the illnesses of hypertension and asteriosclorotic heart disease are compensable. The claimant presented evidence that his illnesses were the result of the nature of his job. The respondent failed to adduce any evidence to show that the illnesses were not work-connected. The Physician's Report indicated that the illnesses were caused by his employment, establishing a link between the sickness and the work. On the employer-employee relationship during leave of absence: The Court affirmed that an employee on leave of absence with pay is considered still an employee. Citing Vda. de Ucang vs. Workmen's Compensation Commission, the Court stated that the employer-employee relationship is not suspended when an employee is on vacation leave with pay. The continued receipt of regular compensation signifies continuous service, aligning with the principle that remuneration is based on actual work rendered. On the presumption of compensability: The Court reiterated the principle established in Vargas vs. Philippine American Embroideries, Inc. that Section 44 of the Workmen's Compensation Act creates a disputable presumption of compensability. This presumption arises not merely from the filing of a claim but from the establishment of a preliminary link between the injury or illness and the employment. Once this link is established, such as the illness supervening during employment, the burden shifts to the employer to prove, by substantial evidence, the absence of a work connection. In this case, the illnesses supervened during employment, and the employer failed to present substantial evidence to rebut the presumption.
Main Doctrine
An illness that supervenes during employment is presumed to be compensable. The employer bears the burden of proving, by substantial evidence, that the illness is not work-connected. An employee on leave of absence with pay is considered to be in continuous service, thus maintaining the employer-employee relationship.