Flores v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Alberto Flores, employed by the Development Bank of the Philippines (DBP) for 33 years, experienced several serious illnesses including diabetes mellitus, asthmatic bronchitis, pneumonitis, and hypertension. These ailments led to his hospitalization and ultimately forced him to retire from service on September 16, 1973, prior to reaching the compulsory retirement age. Procedural History: Flores filed a claim for compensation with the Workmen's Compensation Unit, Regional Office No. VII, asserting his illnesses were service-connected. The Hearing Officer initially granted the award. However, the Development Bank of the Philippines successfully petitioned for the right to controvert the claim, leading to a reconsideration. The Hearing Officer subsequently issued a decision in favor of Flores, finding his illnesses compensable. Upon review, the Workmen's Compensation Commission reversed this decision, absolving DBP of liability and deeming the illnesses not service-connected. The Petition: This case reaches the Supreme Court as a petition for review, treated as a special civil action for certiorari, challenging the Workmen's Compensation Commission's decision. Petitioner Alberto Flores argues that his illnesses were caused or aggravated by his employment, that they supervened during his employment, thus creating a presumption of compensability, and that DBP failed to overcome this presumption. The core issue is whether Flores's illnesses are compensable under the Workmen's Compensation Law, specifically whether they were directly caused by or aggravated by his employment with DBP.
Issue(s)
Whether petitioner Alberto Flores's illnesses, namely diabetes mellitus with asthmatic bronchitis, pneumonitis, and hypertension, are compensable under the Workmen's Compensation Law.
Ruling
The petition is GRANTED. The decision of the Workmen's Compensation Commission is SET ASIDE. The respondent Development Bank of the Philippines is ordered to pay petitioner P6,000.00 as disability compensation, P600.00 as attorney's fees, and P61.00 as administrative fee to the Workmen's Compensation Fund.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that petitioner Alberto Flores's illnesses are compensable under the Workmen's Compensation Law. The Court reiterated the doctrine that once an illness, such as diabetes mellitus, asthmatic bronchitis, pneumonitis, and hypertension, supervenes during the course of employment, there arises a legal presumption that it either arose out of or was at least aggravated by said employment. This presumption shifts the burden of proof to the employer, in this case, the Development Bank of the Philippines (DBP), to prove by substantial evidence that the illness was not work-connected. The Court emphasized, citing Sevilla v. WCC and Abana v. Quisumbing, that it is not required for employment to be the sole factor in the development or aggravation of the illness; it is sufficient that employment contributed, even in a small degree, to the disease. DBP's reliance on medical opinions stating that the illnesses were inherent or not work-related failed to overcome this legal presumption, as mere medical opinion cannot prevail over the presumption established by law, as held in Belmonte v. WCC. The Court further noted that denying benefits to an employee who dedicated 33 years of his life to public service and was forced to retire early due to illnesses supervening during employment violates the constitutional mandate of social justice, as discussed in Gonzales v. WCC. The Workmen's Compensation Act, as social legislation, must be liberally construed to achieve its laudable objective of providing relief to workers.
Main Doctrine
Under the Workmen's Compensation Act, illnesses that supervene during employment are presumed to be compensable, and the burden of proof shifts to the employer to disprove the work-relatedness of the ailment. Mere medical opinion of an employer's physician cannot overcome this legal presumption.