Marasigan v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Felizardo Marasigan, employed as a helper mechanic by Blue Bar Coconut Philippines, Inc., filed a claim for compensation benefits due to sickness (PTB) that allegedly supervened during his employment. The respondent company did not controvert the claim within the period provided by law. Procedural History: The Unit Chief of Regional Office No. 5 issued an award in favor of the claimant, granting compensation benefits, reimbursement of medical expenses, and attorney's fees. The respondent company appealed to the Workmen's Compensation Commission (WCC), which reversed the award and dismissed the claim, contending that the claimant voluntarily stopped working upon reaching retirement age and failed to prove the causal connection between his employment and illness. The Petition: Felizardo Marasigan filed a petition for review of the WCC's decision.
Issue(s)
Whether the Workmen's Compensation Commission erred in reversing the award granted by the Unit Chief. Whether the claimant's illness (PTB) is compensable under the Workmen's Compensation Act. Whether the respondent employer successfully discharged its burden of proof to overcome the presumption of compensability.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the respondent, Blue Bar Coconut Philippines, Inc., to pay the claimant compensation benefits, attorney's fees, and reimburse medical expenses supported by proper receipts, plus administrative fees.
Ratio Decidendi
On the compensability of the illness and the presumption of compensability: The Court reiterated the established principle under Section 44 of the Workmen's Compensation Act, as amended, that an illness supervening during employment is presumed to have arisen out of or at least been aggravated by the employment. This presumption shifts the burden of proof to the employer to demonstrate otherwise. In this case, the Compensation Rating Medical Officer found that the claimant suffered temporary total disability due to PTB which supervened during his employment. The respondent employer failed to present evidence to rebut this presumption. The Court emphasized that the employer's failure to controvert the claim within the statutory period further strengthens the claimant's right to compensation, as it results in the loss of the right to controvert, except on jurisdictional grounds. On the employer's failure to discharge its burden of proof: The Court cited Simon vs. Republic of the Philippines to underscore that even if an illness is not occupational or the causal connection is not explicitly shown, the presumption of compensability under Section 44 of the Act applies. The burden then shifts to the employer to prove that the illness did not arise from or was not aggravated by the employment. The respondent employer in this case failed to discharge this burden. Their contention that the claimant voluntarily stopped working upon reaching retirement age was insufficient to negate the presumption of compensability for an illness that supervened during employment. On the procedural aspect of controversion: The Court noted that the respondent company did not controvert the claim for compensation within the period provided by law. This failure is significant because it means the employer lost its right to controvert the claim, except on grounds of jurisdiction. Therefore, the initial award granted by the Unit Chief, which was based on the presumption of compensability and the employer's failure to controvert, should have been upheld.
Main Doctrine
Under the Workmen's Compensation Act, as amended, there is a presumption that an illness which supervened during employment either arose out of, or was at least aggravated by, said employment, and the burden of proof to overcome this presumption rests upon the employer. Failure to controvert the claim within the statutory period further strengthens the employee's right to compensation.