Tambasen v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Galila Tambasen, an employee of the Province of Negros Occidental (Provincial Health Office), filed a claim for compensation due to an illness diagnosed as Menorrhagia and Metrorrhagia. The respondent province contended that the illness was a purely personal ailment, not work-related, and that the physician's report supporting the claim was not properly signed. Procedural History: The claimant initially filed her case with the Workmen's Compensation Unit at Bacolod City. The Acting Referee ruled in favor of the claimant, ordering the respondent to pay compensation, attorney's fees, and administrative fees. However, the respondent province appealed this decision to the Workmen's Compensation Commission, which then set aside the referee's decision and dismissed the case, deeming the illness not compensable under the Workmen's Compensation Act. The Petition: This petition seeks a review of the Workmen's Compensation Commission's decision. The petitioner argues that the findings of the initial referee, who presided over the entire hearing, deserve more weight. The petitioner contends that her illness, which manifested as severe vaginal bleeding during her pregnancy, was a direct result of the strenuous nature of her work, which involved extensive field duties in rugged and remote areas under adverse weather conditions, thereby establishing a causal connection between her employment and her condition.
Issue(s)
Whether the illnesses of Menorrhagia and Metrorrhagia, characterized by the WCC as 'woman's diseases,' are compensable under the Workmen's Compensation Act (WCA) given the strenuous nature of the petitioner's work.
Ruling
The Supreme Court set aside the decision of the Workmen's Compensation Commission and ordered the respondent Province of Negros Occidental (Provincial Health Office) to pay the petitioner the amount of P3,455.70 as compensation (60% N.S.D.), P345.00 as attorney's fees, and P61.00 as administrative fee.
Ratio Decidendi
On Issue 1: The Supreme Court held that the illness is compensable. Applying Section 44 of the Workmen's Compensation Act (WCA), the Court emphasized that since the illness supervened during the petitioner's employment, a disputable presumption of compensability exists in her favor. Citing Justiniano v. Workmen's Compensation Commission (18 SCRA 677), the Court ruled that the claimant is relieved of the burden of proving causation, and the burden shifts to the employer to prove non-compensability. The evidence clearly established that the petitioner's work required her to travel 140 kilometers, climb mountains, and cross streams in rugged terrain while three months pregnant, which directly led to the bleeding and subsequent surgery. The Court rejected the WCC's reasoning that the condition was merely a 'woman's disease,' noting that the specific strenuous activities of her job were the contributing factors that caused the medical emergency. Relying on Balanga v. Workmen's Compensation Commission (83 SCRA 721), the Court affirmed that the employer failed to provide sufficient evidence to rebut the presumption that the illness arose out of the employment.
Main Doctrine
The illness of an employee is presumed compensable if it supervened during employment. The employer bears the burden of proving that the illness is non-compensable. The claimant need not prove causation when this presumption applies.