Malic v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Abraham F. Malic, a Deputy Provincial Sheriff of Iloilo City, filed a claim for compensation benefits due to an ulcerated new growth at the middle third of the jejunum, second portion of the small intestine, which resulted in his incapacity for work. He sought reimbursement for medical and hospitalization expenses. Procedural History: The claim was filed with the Regional Office No. VII, Workmen's Compensation Unit, Iloilo City. The Department of Justice, through the Undersecretary, sent a Letter of Controversion on September 8, 1972, opposing the claim due to lack of causal connection between the illness and employment. The Solicitor General also filed a second indorsement controverting the claim. The referee treated the notice of controversion as out of time, deemed the claim non-controverted, and rendered an award on October 17, 1972, granting P3,261.41 for disability compensation and medical expenses. A Motion to Set Aside Decision filed by the Solicitor General was denied. The records were elevated to the Workmen's Compensation Commission (WCC). The Petition: The respondent WCC reversed the referee's award on July 18, 1973, absolving the Republic from liability. A motion for reconsideration was denied, leading to the instant petition for review.
Issue(s)
Whether the claim was properly controverted, considering the notice of controversion was filed beyond the reglementary period. Whether the petitioner's ailment is compensable under the Workmen's Compensation Act. Whether the presumption of compensability was successfully rebutted by the employer.
Ruling
The decision of the Workmen's Compensation Commission dated July 18, 1973, is set aside, and the award of the referee dated October 17, 1972, is reinstated in toto.
Ratio Decidendi
On the issue of controversion: The Court noted that the Solicitor General's notice of controversion was filed beyond the reglementary period. While acknowledging conflicting rulings on whether the Solicitor General or the head of the department is the proper official to file the controversion, the Court found it unnecessary to definitively pass upon this issue as the petition had sufficient merit on other grounds. The critical point was that the employer failed to rebut the presumption of compensability. On the compensability of the ailment: The Commission reversed the referee's award, stating the ailment was not peptic ulcer but a new growth of the small intestine, and that the case did not fall within the Act's protection. The Commission also questioned the clear medical proof and suggested the growth would have progressed regardless of work. However, the Supreme Court emphasized that under Section 44 of the Act, there is a presumption that the claim comes within the provisions of the Act in the absence of substantial evidence to the contrary. The Court reiterated that an employee is freed from the burden of proving causation or aggravation if the illness supervened in the course of employment. On the rebuttal of the presumption of compensability: The Court held that the employer failed to overturn the legal presumption of compensability by adducing clear and convincing evidence that the petitioner's ailment was not attributable to the nature of his employment. The presumption of compensability, established in a long line of cases, dispenses with the need for proof of the exact medical cause of the illness as long as it occurred or was aggravated during employment. Since the employer did not successfully rebut this presumption, it could not be absolved from its liability to pay compensation.
Main Doctrine
The presumption of compensability under the Workmen's Compensation Act is a legal presumption that dispenses with the need for proof of causation, and it is not necessary for the Court to inquire into the exact cause of the petitioner's ailment as long as it occurred or was aggravated in the course of employment. The employer must rebut this presumption with clear and convincing evidence.