Enriquez v. Republic
REITERATIONFacts
The Antecedents: Petitioner Domingo C. Enriquez Sr. served the government from September 18, 1952, eventually transferring to the National Irrigation Administration (NIA) as Senior Security Guard on October 12, 1964. On February 19, 1973, he suffered a stroke due to hypertension, resulting in paralysis of his right side, slurred speech (dysarthria), and total incapacity for work. He also had diabetes mellitus, and his physician advised against further work due to the risk of aggravating his condition or causing another stroke. At the time of his incapacity and retirement in 1973, he was 58 years old and earning P3,612.00 annually. Procedural History: On July 5, 1973, petitioner filed a claim for compensation. The Solicitor General controverted the claim. On January 27, 1975, the Acting Referee of Regional Office No. 4 granted petitioner disability benefits and reimbursement for medical expenses. The Solicitor General moved for reconsideration, which was denied. The case was elevated to the Workmen's Compensation Commission (WCC). The Petition: On December 9, 1975, the WCC reversed the Acting Referee's decision, absolving the NIA from liability, holding that hypertension and diabetes mellitus are not disabling ailments as they are caused by aging and can be cured by proper food and medication. Petitioner filed a petition for review on certiorari, insisting on the compensability of his ailment and seeking the reversal of the WCC decision.
Issue(s)
Whether petitioner's disability due to hypertension is compensable under the Workmen's Compensation Act. Whether the statutory presumption of compensability applies and was overcome by the respondent. Whether petitioner's hypertension was aggravated by the nature of his employment.
Ruling
The decision of the Workmen's Compensation Commission absolving respondent Republic (NIA) from liability is REVERSED and SET ASIDE, and the award made by the Acting Referee in favor of petitioner is REVIVED and REINSTATED.
Ratio Decidendi
On the compensability of petitioner's disability due to hypertension: The Court found merit in the petition and held that petitioner's disability due to hypertension is compensable. The statutory presumption of compensability under Section 44(1) of the Workmen's Compensation Act is applicable. This presumption states that in the absence of substantial evidence to the contrary, a claim comes within the provisions of the Act. The petitioner's assertion that he was in good health when he started working with NIA in 1964 was not disputed, and his hypertension symptoms appeared in January 1970, indicating it supervened during his employment. Therefore, it is presumed to be service-connected and compensable, a principle consistently upheld by the Court in numerous cases. The burden of proof shifts to the employer to demonstrate that the illness, though occurring during employment, did not arise from it or was not aggravated by it. On the application of the statutory presumption and the employer's burden of proof: The respondents failed to discharge their burden of proof to overcome the presumption of compensability. The WCC and the Minister of Labor merely claimed that hypertension is an 'ordinary disease of life' to which the general public is exposed and can be contracted anywhere. The Acting Solicitor General echoed this, adding that it was not necessarily contracted due to the nature of petitioner's work or aggravated by it, and that the stroke was due to his hypertensive condition, not his work. The Court found these assertions to be bare and inadequate to destroy the statutory presumption. Evidence required to overcome this presumption must be substantial, such that a reasonable mind accepts it as adequate to support a conclusion, which was not met by the respondents. No attempt was made to show that the hypertension was not service-connected or had not been aggravated by the work, thus the presumption of compensability prevails. On the aggravation of petitioner's hypertension by the nature of his employment: Even assuming, arguendo, that the hypertension was not directly service-connected, the disability is still compensable under the rule of aggravation, as enunciated in Belmonte vs. WCC. The petitioner continued performing his duties despite his ailment, which required him to be always on alert to protect NIA properties and lives. His work strain was compounded by frequent night duties, increasing the risks to his life and health. The nature of his work caused him worries, apprehension, fear, and threats, contributing to his physical and emotional instability, which ultimately predisposed him to his cerebrovascular attack. The Court concluded that, similar to the Belmonte case, the petitioner's illness falls within the rule of aggravation provided in Section 2 of the Workmen's Compensation Act, as the nature of his work and duties did aggravate his illness.
Main Doctrine
The statutory presumption of compensability under Section 44(1) of the Workmen's Compensation Act applies to illnesses that supervene in the course of employment, and the employer bears the burden of proving by substantial evidence that the illness is not service-connected or aggravated by employment. Bare assertions that an illness is an 'ordinary disease of life' are insufficient to overcome this presumption. Furthermore, even if an illness is not directly service-connected, it is compensable if it is aggravated by the nature of the employment.