Social Security System v. Latuño
REITERATIONFacts
The Antecedents: Leonora H. Latuno (claimant) was employed by the Social Security System (SSS) from March 3, 1959, until June 1, 1969, holding various positions and eventually becoming a Unit Supervisor. In 1967, she suffered from arthritis, which worsened in 1969, leading her to request retirement due to her ailment. Procedural History: On December 31, 1972, Latuno filed a claim for disability compensation. The SSS filed an employer's report and a motion for reinstatement of its right to controvert the claim. The Acting Referee ordered the SSS to pay P6,000.00 as disability compensation and P66.00 as administrative costs. The SSS appealed to the Workmen's Compensation Commission (WCC), which affirmed the referee's decision. The Petition: The SSS filed a petition for review, questioning the WCC's decision. The main issue was whether the claimant was afflicted with Osteo-Arthritis in the course of her employment.
Issue(s)
Whether the claimant's Osteo-Arthritis supervened during her employment with the Social Security System. Whether the claimant's illness is compensable under the Workmen's Compensation Act. Whether the claim was filed beyond the prescribed period.
Ruling
The Supreme Court affirmed the decision of the Workmen's Compensation Commission, with a modification regarding attorney's fees. The Social Security System was ordered to pay Leonora H. Latuno P6,000.00 as disability compensation and P600.00 as attorney's fees.
Ratio Decidendi
On whether the claimant's Osteo-Arthritis supervened during her employment with the Social Security System: The Court found that the evidence sufficiently established that the claimant was afflicted with Osteo-Arthritis in the course of her employment. Medical evidence showed she had been on sick leave multiple times and was diagnosed with Arthritis and subsequently Osteo-Arthritis by GSIS General Hospital physicians. This ailment rendered her physically incapable of performing her duties, compelling her to retire. The Court noted that she was only 45 years old and on an upward career trajectory, indicating she would not have left her position unless physically disabled. On whether the claimant's illness is compensable under the Workmen's Compensation Act: The Court held that there is ample evidence linking the claimant's ailment to her employment. Dr. Arturo Fajardo's physician's report and testimony indicated that the claimant's ailment was aggravated by her employment, citing physical stress and exposure to air-conditioned rooms as contributing factors. Under the law, in the absence of substantial evidence to the contrary, the physician's statements are presumed true. Furthermore, the Court invoked the disputable presumption that an illness supervening during employment arose out of or was at least aggravated by the employment, relieving the claimant of the burden of proving causation. The SSS failed to adduce sufficient evidence to overcome this presumption. On whether the claim was filed beyond the prescribed period: The Court dismissed the petitioner's contention that the claim was filed beyond the period prescribed by Section 24 of the Workmen's Compensation Act. It reiterated the settled rule that failure to comply with Section 24 is non-jurisdictional and does not bar proceedings. Moreover, the Court cited jurisprudence holding that compensation under the Workmen's Compensation Act is a statutory liability that prescribes in ten (10) years, pursuant to Article 1144(2) of the Civil Code of the Philippines.
Main Doctrine
The illness of an employee that supervened during employment is presumed to have arisen out of or been aggravated by such employment, shifting the burden of proof to the employer to disprove compensability. Failure to file a claim within the prescribed period is non-jurisdictional and does not bar proceedings, as compensation is a statutory liability prescribing in ten years.