Micu v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Estelita B. Micu, a technician employed by the Bureau of Agricultural Extension, filed a claim for compensation and medical expense reimbursement due to an illness, Myoma Uteri, which she alleged supervened during and was aggravated by her employment. The illness required two surgical operations and resulted in significant medical expenses and periods of incapacitation, leading to her eventual optional retirement. Procedural History: The claim was initially heard by the Chief, Workmen's Compensation Unit, Regional Office No. 2, who, after an ex-parte hearing due to the respondent's absence, ruled in favor of Micu, awarding her compensation and medical expense reimbursement. The respondent, Republic of the Philippines (Bureau of Agricultural Extension), received this decision on August 4, 1975, but filed a petition to elevate the records for relief from judgment on September 30, 1975, beyond the period for a motion for reconsideration. The Workmen's Compensation Commission subsequently reversed the initial decision, absolving the respondent of liability. The Petition: This case comes before the Supreme Court on a petition for review filed by Estelita B. Micu. The petitioner argues that her illness, Myoma Uteri, contracted during her employment and aggravated by the nature of her field work, particularly during inclement weather and menstrual periods, should be presumed compensable under Section 44 of the Workmen's Compensation Act. She contends that the respondent failed to rebut this presumption, as they adduced no evidence to disprove the causal link or aggravation of her condition by her employment. The petition seeks to set aside the decision of the Workmen's Compensation Commission and reinstate the award granted by the Chief of the Workmen's Compensation Unit.
Issue(s)
Whether the respondent's justification for the late filing of its petition for relief from judgment is valid. Whether the petitioner's illness, Myoma Uteri, is compensable under the Workmen's Compensation Act, as amended, considering it supervened during her employment and was allegedly aggravated by the nature of her work. Whether the presumption of compensability under Section 44 of the Workmen's Compensation Act was rebutted by the respondent.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the respondent, Republic of the Philippines (Bureau of Agricultural Extension), to pay the claimant compensation benefits and reimbursement for medical expenses, attorney's fees, and administrative fees.
Ratio Decidendi
On the validity of the late filing: The Court held that the respondent's justification of pressure and volume of work is not a valid excuse for not filing an appeal or petition for relief on time, citing previous rulings. However, the Court proceeded to review the merits of the petition. On the compensability of the illness: The Court found that the petitioner contracted her illness during her employment and that the illness was aggravated by her employment. The nature of her work, which involved field work even during inclement weather and profuse bleeding during menstrual periods, supported the claim of aggravation. The Court emphasized that the illness supervened during her employment. On the presumption of compensability: The Court reiterated the presumption under Section 44 of the Workmen's Compensation Act, as amended, that an illness which supervened during employment either arose out of, or at least was aggravated by, said employment. This presumption shifts the burden of proof to the employer. In this case, the respondent failed to adduce any evidence to rebut this presumption, making the claim compensable. The Court cited Simon versus Republic of the Philippines in support of this principle.
Main Doctrine
Under the Workmen's Compensation Act, illness supervening during employment is presumed to have arisen out of or at least been aggravated by said employment, shifting the burden of proof to the employer to rebut this presumption. Failure of the employer to adduce evidence to rebut this presumption renders the claim compensable.