Enriquez v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Sofia L. Enriquez, the petitioner, was employed as a seamstress by Philippine Gloves Company starting in 1960, working approximately 8 hours a day, seven days a week. In June 1965, she became ill with a kidney ailment, specifically Pyonephrosis of the right kidney, which necessitated surgery (nephrectomy) and a 24-day hospital confinement. She resumed working for the company thereafter and continued until sometime in 1973, when she stopped working, alleging it was due to her illness. Procedural History: Petitioner filed a claim for compensation with the Department of Labor on March 21, 1975, for her kidney ailment. An Acting Referee awarded her P3,411.20 in compensation benefits, finding the illness to be service-connected or aggravated by her employment, and presuming compensability. The employer sought reconsideration, which was denied, but the case records were elevated to the Workmen's Compensation Commission (WCC). The WCC reversed the award, holding that the petitioner failed to prove incapacitation for labor, as she continued working after surgery and was terminated for abandonment. The WCC also deemed a physician's report from 1975 inadmissible as it was too distant from her cessation of work. The Petition: This petition for review on certiorari was filed by the petitioner in forma pauperis seeking to overturn the WCC's decision. The petitioner argues that the WCC committed a grave abuse of discretion by reversing the Acting Referee's award, which was contrary to established jurisprudence on Workmen's Compensation. She contends that the presumption of compensability applies because her illness supervened during her employment, and the burden was on the employer to disprove this presumption, which it failed to do. Furthermore, she asserts that the medical evidence, including clinical records and a physician's report, supports her claim and is admissible, contrary to the WCC's ruling.
Issue(s)
Whether the Workmen's Compensation Commission (WCC) committed grave abuse of discretion in reversing the Referee's award by requiring the claimant to prove incapacity despite the illness having supervened during the course of employment.
Ruling
The Supreme Court reversed the decision of the respondent Commission, setting aside the reversal and ordering the respondent employer to pay petitioner compensation benefits, reimburse medical expenses, and pay administrative fees.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Workmen's Compensation Commission (WCC) committed grave abuse of discretion because its reversal was contrary to prevailing jurisprudence and the evidence on record. Applying Paraiso v. Castelo-Sotto, the Court held that since Enriquez's kidney ailment supervened in June 1965 during her employment, she enjoyed the legal presumption of compensability. This presumption shifts the burden of proof to the employer to show, through substantial evidence, that the illness was not service-connected; here, the employer failed to provide such evidence. The Court further noted that under Section 49 of the Workmen's Compensation Act, physician's reports and clinical records are admissible as proof of the fact in dispute, regardless of when the medical treatment was administered, provided they relate to the compensation claim. The 1975 report by Dr. Tomacruz successfully linked the petitioner's disability to the 1965 nephrectomy, which was a compensable injury. Finally, the Court dismissed the employer's defense of abandonment, finding it inconsistent with their own records showing that Enriquez had taken sick leaves immediately prior to her separation from the company.
Main Doctrine
The presumption of compensability applies when an illness supervenes in the course of employment. The burden to overthrow this presumption rests on the employer. Failure to present substantial evidence to disconnect the illness from employment renders the presumption conclusive.