Perez v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Melanio Perez, the petitioner, filed a claim for compensation alleging that he contracted pulmonary tuberculosis in the course of his employment as a carpenter with the Republic of the Philippines (Bureau of Public Highways). He stated that he stopped working on December 15, 1969, due to his illness and had notified his superior of his ailment in December 1969. Supporting documents included a physician's report diagnosing pulmonary tuberculosis caused by the stress and strain of employment, a Quezon Institute Case Record showing confinement for PTB in 1970, and his service record indicating employment from February 1, 1949, to December 15, 1969. Procedural History: An Acting Referee of the Department of Labor awarded petitioner disability benefits, attorney's fees, and administrative fees, finding the claim uncontroverted and the illness to have supervened during employment. The respondent employer, through the Solicitor General, moved for reconsideration, arguing the illness was not compensable, the claim was filed late, and the employee had retired without disability. The motion was denied, but the case was elevated for review. The Workmen's Compensation Commission reversed the Acting Referee's decision, finding that the petitioner contracted the disabling illness after retirement and thus outside the scope of the Workmen's Compensation Act. The Petition: The petitioner seeks review on certiorari, contending that the respondent Commission gravely abused its discretion by concluding his tuberculosis was contracted after retirement, which he argues is contrary to the undisputed evidence. He asserts that the Commission's finding lacks evidentiary support and that the evidence shows he contracted the ailment in 1967 and stopped working due to it on December 15, 1969, before any retirement. The petitioner argues that the presumption of compensability for illnesses contracted during employment applies, and the employer failed to present substantial evidence to overcome this presumption.
Issue(s)
Whether the respondent Commission gravely abused its discretion in concluding that the petitioner contracted his PTB ailment after he retired from the service. Whether the petitioner's illness, pulmonary tuberculosis, is compensable under the Workmen's Compensation Act.
Ruling
The Supreme Court reversed and set aside the decision of the respondent Commission. The respondent employer was ordered to pay the petitioner P6,000.00 as disability benefits, his medical expenses supported by receipts, and attorney's fees equivalent to five percent (5%) of the total award. The successor of the defunct respondent Commission was ordered to pay administrative fees.
Ratio Decidendi
On the issue of whether the petitioner contracted his PTB ailment after retirement: The Court found the Commission's conclusion to be bereft of evidentiary support and contrary to the undisputed evidence. There was no evidence presented by the respondent employer to show that the petitioner had retired. On the contrary, the evidence indicated that he contracted the ailment in 1967 and stopped working on December 15, 1969, due to his illness. The physician's report to this effect was not refuted by any evidence from the employer. The Court noted that the respondent employer never appeared in the hearing, thus submitting no rebutting evidence. The Court reasoned that petitioner's cessation of work on December 15, 1969, was due to his PTB ailment, as he did not retire or resign, and the employer provided no other reason for his stoppage. Given his approximately 20 years of service, he would not have stopped working without a compelling reason. His subsequent hospitalization at the Quezon Institute further supported the presumption that he was disabled by his tuberculosis at the time he stopped working. The Court also took judicial notice that employees afflicted with PTB, especially in its incipient stage, often continue working due to the need to earn a living, citing several previous cases where workers with PTB continued employment despite their condition. On the compensability of the petitioner's illness: The Court reiterated the principle that when an illness supervenes in the course of employment, there is a presumption that it either arose out of or was at least aggravated by the employment. This presumption shifts the burden of proof to the employer to present substantial evidence to overthrow it. The respondent employer failed to adduce any substantial evidence to overcome this presumption. Furthermore, Section 2 of the Workmen's Compensation Act expressly lists tuberculosis as a compensable illness when contracted in the course of employment, whether directly caused by, aggravated by, or the result of the nature of such employment. The Court affirmed that in numerous cases involving similar work and circumstances, tuberculosis has been ruled as an occupational disease and therefore compensable. The Court also found that the right of the petitioner to compensation was uncontroverted, and thus, the respondent employer's defenses were barred.
Main Doctrine
The presumption of compensability for an illness that supervened in the course of employment shifts the burden of proof to the employer to present substantial evidence to overthrow it. Failure to do so renders the claim compensable, especially when the illness, like tuberculosis, is listed as compensable under the Workmen's Compensation Act.