Reyes v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Brigida Reyes, widow of the late Mariano Reyes, filed a claim for death compensation against the Republic of the Philippines (National Irrigation Administration) after her husband, a carpenter, died on July 4, 1973. Mariano Reyes was employed by the National Irrigation Administration since May 14, 1973, with a daily wage of P9.17, working 8 hours a day, 5 days a week, and often working overtime until midnight. He was found dead at the bunkhouse of Campsite, Pantabangan, Nueva Ecija. The deceased and claimant had seven minor children who were dependent on his earnings. The widow spent approximately P1,000.00 for funeral services. Procedural History: The Hearing Officer of Regional Office No. 1 found the claim compensable and ordered the respondent to pay death benefits, burial expenses, and attorney's fees. The Republic of the Philippines (National Irrigation Administration) appealed to the Workmen's Compensation Commission (WCC), which reversed the Hearing Officer's decision, dismissing the claim on the ground that the illness (hemorrhagic pancreatitis) was neither caused nor aggravated by the deceased's employment. The Petition: Brigida Reyes filed a petition for review, contending that the illness of Mariano Reyes was caused or aggravated by his work as a carpenter for the National Irrigation Administration.
Issue(s)
Whether the death of Mariano Reyes arose out of and in the course of his employment. Whether the illness of hemorrhagic pancreatitis was caused or aggravated by his employment as a carpenter for the National Irrigation Administration.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The respondent, Republic of the Philippines (National Irrigation Administration), is ordered to pay the petitioner and her minor children the sum of Five Thousand Seven Hundred Twenty-two Pesos (P5,722.00) as death benefit, plus Two Hundred Pesos (P200.00) as burial expenses; to pay the petitioner the amount of Five Hundred Seventy Two Pesos (P572.00) as attorney's fees; and to pay the successor of the Workmen's Compensation Commission the amount of Fifty Seven Pesos (P57.00) as administrative fee.
Ratio Decidendi
On the issue of whether the death of Mariano Reyes arose out of and in the course of his employment: The Court held that it is undisputed that the illness of the late Mariano Reyes supervened during his employment with the National Irrigation Administration. Under Section 44 of the Workmen's Compensation Act, there is a disputable presumption that the claim is compensable. This presumption relieves the claimant of the duty to prove causation, shifting the burden of proof to the employer to demonstrate that the sickness is not compensable. The respondent failed to discharge this burden. The evidence showed that Mariano Reyes worked overtime until midnight before he died. The death certificate, issued by the project physician, indicated "Over fatigue" as a condition contributing to the death, alongside "Hemorrhagic Pancreatitis" as the direct cause. The Camp Superintendent also admitted the deceased worked overtime and expressed his belief that the death was connected to his work. Therefore, the death arose out of and in the course of his employment. On the issue of whether the illness of hemorrhagic pancreatitis was caused or aggravated by his employment: The Court found that the evidence adduced supported the claim that the illness was caused or aggravated by his employment. The claimant testified that prior to his employment with the respondent, the deceased complained of eye and stomach pains. During his vacation from NIA work, he appeared pale, yellowish, and thin, indicating the arduous nature of his work. He consistently worked overtime from 6:00 p.m. to 12:00 midnight. The respondent's own witness confirmed the overtime work. The death certificate explicitly listed "Over fatigue" as a contributing factor to his death, directly linking it to the nature of his work. The employer failed to present evidence to rebut the presumption of compensability. Thus, the illness was directly caused by the nature of his work with the National Irrigation Administration.
Main Doctrine
The employer failed to discharge its burden of proof to show that the employee's death due to hemorrhagic pancreatitis and over fatigue was not caused or aggravated by his employment, thus the claim for death benefits is compensable.