Villodres v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for death compensation and burial expenses filed by Potenciana Villodres on behalf of her deceased husband, Angel F. Villodres, Sr. Angel F. Villodres, Sr., a classroom teacher employed by the Bureau of Public Schools, contracted an illness diagnosed as Hypertension, essential secondary to nephritis Rheumatoid arthritis. This illness caused him to temporarily stop working on October 2, 1972, and ultimately led to his death on August 29, 1975. 2. Procedural History: Angel F. Villodres, Sr. initially filed a claim for disability benefits on March 25, 1975. Following his death, his widow, Potenciana Villodres, filed a notice and claim for compensation and reimbursement of burial expenses. The Acting Referee of Regional Office No. 7 awarded the claimant P4,880.00 in death compensation and burial expenses. The respondent, Republic of the Philippines (Bureau of Public Schools), moved for reconsideration, which was denied. The case was then elevated to the Workmen's Compensation Commission. The Commission reversed the Acting Referee's decision, dismissing the case on the grounds that the death occurred nearly three years after the initial disability, thus lacking a cause of action under their interpretation of the law. 3. The Petition: This case comes before the Supreme Court via a petition for review of the Workmen's Compensation Commission's decision. The petitioner argues that the Commission erred in dismissing the claim. Specifically, the petitioner contends that the two-year period for compensation should not have been calculated from October 2, 1972, but rather from August 31, 1974, the date Angel F. Villodres, Sr. was forced to retire due to his illness, as he was not fully disabled from work on the earlier date and continued to work intermittently. The petitioner also highlights that the respondent did not controvert the claim, thereby renouncing non-jurisdictional defenses, and that the illness is presumed compensable as it supervened during employment.
Issue(s)
Whether the Workmen's Compensation Commission erred in reversing the award granted by the Acting Referee. Whether the claim for death compensation is compensable despite the death occurring more than two years after the initial disability.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The respondent, Republic of the Philippines (Bureau of Public Schools), is ordered to pay the claimant P4,880.00 as death compensation and reimbursement of burial expenses, to reimburse medical expenses supported by receipts, and to pay attorney's fees of P488.00. Administrative fees of P61.00 are also to be paid.
Ratio Decidendi
On the issue of compensability and the two-year period: The Workmen's Compensation Commission erred in computing the two-year period from October 2, 1972, the date of temporary cessation of work. The late Angel F. Villodres, Sr. was able to return to work after October 2, 1972, and only retired on August 31, 1974, due to his illness. Therefore, the two-year period should be reckoned from August 31, 1974, the date of actual disability and retirement, not from the date of temporary incapacity. The illness supervened during his employment, creating a disputable presumption of compensability under Section 44 of the Workmen's Compensation Act, as amended. The claimant is relieved of the burden of proving causation, and the employer bears the burden of proving non-compensability. The respondent's failure to controvert the claim further strengthens the presumption, deeming it to have renounced non-jurisdictional defenses. The claim is therefore compensable. On the award of compensation and expenses: Given that the illness is compensable and the respondent did not controvert the claim, the award of P4,880.00 as death compensation and reimbursement of burial expenses by the Acting Referee was proper. Additionally, the petitioner is entitled to reimbursement of medical expenses incurred by the deceased, provided they are supported by proper receipts, and attorney's fees, as the case warrants.
Main Doctrine
The two-year period for claiming compensation for death due to illness, under the Workmen's Compensation Act, should be reckoned from the date of actual disability or retirement due to illness, not from the date of temporary cessation of work if the employee was able to return to work thereafter.