Zapata v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioners, heirs of the deceased Fernando Zapata, filed a claim for death benefits under the Workmen's Compensation Act. Fernando Zapata was employed by respondent San Miguel Corporation as a laborer since 1948 and later as an assistant foreman. He died on January 24, 1966, due to 'hepatoma with Superimposed amoebic abscess,' an illness allegedly caused or aggravated by his employment. Procedural History: The Acting Chief Referee of Regional Office No. 4, Manila, rendered a decision awarding death benefits and burial expenses to the claimants. The respondent, San Miguel Corporation, filed a motion for reconsideration, and the case was elevated to the Workmen's Compensation Commission (WCC). The WCC reversed the Referee's decision, absolving San Miguel Corporation from liability, finding that the illness was neither caused nor aggravated by the deceased's work. The Petition: The heirs of Fernando Zapata filed a petition for review of the WCC's decision.
Issue(s)
Whether the illness of Fernando Zapata, which supervened during his employment, is compensable under the Workmen's Compensation Act. Whether the San Miguel Corporation is liable for death benefits and burial expenses.
Ruling
The decision of the Workmen's Compensation Commission is set aside. San Miguel Corporation is ordered to pay the petitioners P6,000.00 as death benefit, P200.00 as burial expenses, and P600.00 as attorney's fees. The successor of the Workmen's Compensation Commission is to be paid P61.00 as administrative fees.
Ratio Decidendi
On whether the illness of Fernando Zapata is compensable: The illness of Fernando Zapata, 'hepatoma with Superimposed amoebic abscess,' supervened during his employment with San Miguel Corporation. Under Section 44 of the Workmen's Compensation Act, there is a disputable presumption that an illness supervening during employment is compensable. This presumption shifts the burden of proof to the employer to demonstrate that the ailment is not compensable. The Supreme Court noted that the employer, San Miguel Corporation, failed to adduce evidence to prove that Fernando Zapata's ailment was neither caused nor aggravated by his employment. Furthermore, the fact that San Miguel Corporation defrayed the expenses for Fernando Zapata's last hospitalization and operation serves as an admission of the merit of the claim, reinforcing the presumption of compensability. The Court reiterated the principle that the claimant is relieved of the duty to prove causation when the illness arises out of employment, as legally presumed. On whether San Miguel Corporation is liable for death benefits and burial expenses: Given the presumption of compensability and the failure of the employer to rebut it, San Miguel Corporation is liable for the death benefits and burial expenses. The Hearing Officer's computation for the death benefit, based on Sections 6(b), 9, 10, and 12 of the Workmen's Compensation Act, was found to be correct. The claimants, as widow and five minor children, are entitled to 60% of the average weekly wage for 208 weeks, not exceeding P6,000.00. The deceased's daily wage of P10.25, working six days a week, exceeded P50.00 weekly. Sixty percent of P50.00 is P30.00, which, multiplied by 208 weeks, amounts to P6,240.00, reduced to the maximum of P6,000.00. Additionally, under Section 8, the widow is entitled to P200.00 for burial expenses. Attorney's fees were also awarded.
Main Doctrine
The illness of an employee, having supervened during employment, is disputably presumed to be compensable under the Workmen's Compensation Act. The employer bears the burden of proving that the ailment is not compensable. Payment of hospitalization and operation expenses by the employer constitutes an admission of the claim's merit.