Alabat v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Aproniano Alabat, a public school teacher since 1931, contracted hypertension, hernia, appendicitis, and hepatitis during his employment. He retired on November 2, 1973, at the age of 63. Procedural History: Alabat filed a claim for compensation with the Workmen's Compensation Unit, Regional Office No. XIX, Tacloban City. The Hearing Officer found the claim compensable and ordered the respondent, the Department of Education and Culture, to pay P6,000.00. The Department of Education and Culture filed a motion for reconsideration, arguing that hypertension is merely a symptom. The Petition: This is a petition to review the decision of the Workmen's Compensation Commission which reversed the decision of the Acting Referee.
Issue(s)
Whether the illnesses contracted by the petitioner during his employment are compensable under the Workmen's Compensation Act. Whether the respondent failed to rebut the presumption of compensability.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The respondent, Republic of the Philippines (Department of Education and Culture), is ordered to pay the claimant P6,000.00 as compensation benefits, reimburse medical expenses supported by proper receipts, pay attorney's fees of P600.00, and pay administrative fees of P61.00.
Ratio Decidendi
On whether the illnesses contracted by the petitioner during his employment are compensable under the Workmen's Compensation Act: The Court affirmed that the illnesses contracted by the petitioner, Aproniano Alabat, during his employment as a public school teacher are compensable. It was established that Alabat suffered from hypertension, hernia, appendicitis, and hepatitis. The fact that these illnesses supervened during his period of employment is crucial for establishing compensability under the Workmen's Compensation Act. The Court noted that Alabat retired at the age of 63 due to his diseases, particularly hypertension which had become complicated, indicating a direct impact on his ability to continue working. On whether the respondent failed to rebut the presumption of compensability: The Court held that the respondent, the Department of Education and Culture, failed to rebut the presumption of compensability established by Section 44 of the Workmen's Compensation Act. This section creates a disputable presumption that illnesses contracted during employment are caused or at least aggravated by the work performed. The respondent's argument that hypertension is merely a symptom and not a disease was insufficient to overcome this presumption. The Court emphasized that the employer bears the burden of demonstrating, by substantial evidence, the absence of a work connection, a burden which the respondent failed to discharge in this case. The Court reiterated the principle that the presumption of compensability should be interpreted broadly to advance the beneficent purpose of the Act to protect workmen and their families, resolving all doubts in their favor.
Main Doctrine
Under Section 44 of the Workmen's Compensation Act, there is a presumption that illnesses contracted during employment were caused or aggravated by work, and the employer must rebut this presumption with substantial evidence. The presumption should be interpreted broadly to protect workmen.