Macanip v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Camilo Macanip, employed as a clerk by the Municipality of Jaro, Leyte, filed a claim for disability compensation alleging he contracted schistosomiasis due to the nature of his work, compelling him to go on sick leave on May 15, 1971. Camilo Macanip died on October 14, 1972. His widow, Juana Vda. de Macanip, filed a motion to convert the claim from disability to death benefits. Procedural History: The Acting Referee of Regional Office No. 4 awarded death compensation, burial expenses, and attorney's fees. The Municipality of Jaro appealed to the Workmen's Compensation Commission (WCC), which reversed the Acting Referee's decision, absolving the municipality of liability. The WCC found no evidence of treatment for any ailment before May 14, 1971, nor evidence that the cause of death (Cardiac Heart Failure due to Pericardial Effusion) was traceable to his employment. The Petition: Petitioners sought review of the WCC decision, arguing that the sickness (schistosomiasis) was contracted during employment and that the presumption of compensability under the Workmen's Compensation Act was not rebutted.
Issue(s)
Whether the death of Camilo Macanip is compensable under the Workmen's Compensation Act. Whether the Workmen's Compensation Commission erred in reversing the decision of the Acting Referee.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The Municipality of Jaro, Province of Leyte, is ordered to pay petitioners death compensation, burial expenses, reimbursement of medical expenses (if supported by receipts), and attorney's fees. The successor of the Workmen's Compensation Commission is to be paid administrative fees.
Ratio Decidendi
On whether the death of Camilo Macanip is compensable under the Workmen's Compensation Act: The Court held that the sickness of Camilo Macanip supervened during his employment with the Municipality of Jaro, Leyte. Consequently, there is a disputable presumption that the claim is compensable under Section 44 of the Workmen's Compensation Act. This presumption relieves the claimant of the duty to prove causation, shifting the burden of proof to the employer to establish that the illness is non-compensable. The claimant, Juana Vda. de Macanip, did not rely solely on this presumption but also adduced evidence that Camilo Macanip contracted schistosomiasis due to the nature of his work, which involved traveling to remote barrios and drinking water from unfiltered sources containing elements from dangerous snails. The respondent municipality failed to rebut this presumption and the claimant's evidence. Therefore, the death is compensable. On whether the Workmen's Compensation Commission erred in reversing the decision of the Acting Referee: The Court found that the WCC erred in reversing the Acting Referee's decision. The WCC's grounds for reversal, namely the lack of evidence of treatment before May 14, 1971, and the lack of evidence tracing the cause of death to employment, were insufficient to overcome the disputable presumption of compensability. The evidence presented by the claimant, including the nature of Camilo Macanip's work and the contraction of schistosomiasis during his employment, established a prima facie case for compensation. The municipality's failure to present evidence to disprove the causal link between the illness and employment meant the presumption stood. The Court reinstated the award granted by the Acting Referee, finding the computation of death compensation and burial expenses to be correct.
Main Doctrine
The sickness of an employee that supervened during employment is disputably presumed to be compensable under the Workmen's Compensation Act, shifting the burden of proof to the employer to establish that the illness is non-compensable. The claimant is relieved of the duty to prove causation.