Larioma v. Maria Cristina Fertilizer Corporation
REITERATIONFacts
1. The Antecedents: Domingo Larioma, employed as a maintenance man by Maria Cristina Fertilizer Corporation, filed a claim for compensation due to two illnesses: acute hepatitis, which caused him to stop working in May 1971, and coronary heart disease, which led him to stop working again in July 1971. He alleged these illnesses arose during his employment. 2. Procedural History: Larioma's claim was initially dismissed by Referee Rodolfo S. Milado of Regional Office No. XI on September 16, 1974, for lack of substantial evidence. The case was then elevated to the Workmen's Compensation Commission, which was subsequently abolished. The Workmen's Appeal and Review Staff took over the functions of the defunct commission. On March 1, 1977, the Minister of Labor affirmed the referee's decision, finding no evidence to warrant reversal. 3. The Petition: This case is a petition for review of the Minister of Labor's decision. The petitioner argues that his illnesses, acute hepatitis and coronary heart disease, which occurred during his employment, are presumed to be compensable under the Workmen's Compensation Act. He contends that the employer failed to present evidence to rebut this presumption and prove that the ailments were not caused or aggravated by his work. The core issue is the compensability of his illnesses.
Issue(s)
Whether the ailments of Domingo Larioma are compensable. Whether the respondent employer successfully adduced evidence to prove that the ailments were neither caused nor aggravated by the employment.
Ruling
The decision sought to be reviewed is set aside. Maria Cristina Fertilizer Corporation is ordered to pay the petitioner P6,000.00 as disability compensation, reimburse medical expenses duly supported by receipts, pay P600.00 as attorney's fees, and pay P61.00 as administrative fee to the successor of the Workmen's Compensation Commission.
Ratio Decidendi
On the compensability of the ailments: The Court held that it is a fact that Domingo Larioma became ill of acute hepatitis and coronary heart disease during his employment. The illnesses having supervened during his employment, there is a disputable presumption that the claim is compensable under Section 44 of the Workmen's Compensation Act. This presumption relieves the claimant of the duty to prove causation, as it is legally presumed that the illnesses arose out of the employment. The burden of proof is thus shifted to the employer to demonstrate that the ailments are not compensable. The Court noted that the private respondent, Maria Cristina Fertilizer Corporation, failed to adduce evidence to prove that the petitioner's ailments were neither caused nor aggravated by his employment as a maintenance worker in its pyrite-acid plant. Therefore, the petitioner is entitled to compensation for complete disability and reimbursement of medical expenses. On the employer's failure to prove non-compensability: The Court found that the respondent employer did not present any evidence to rebut the disputable presumption of compensability. The failure to discharge this burden of proof means that the presumption stands, and the claim must be considered compensable. The employer's inaction or failure to present substantial evidence to the contrary is fatal to its defense against the claim. Consequently, the petitioner's claim for compensation for his illnesses, acute hepatitis and coronary heart disease, which occurred during his employment, is upheld.
Main Doctrine
When an illness supervenes during employment, there is a disputable presumption that the claim is compensable, and the burden shifts to the employer to prove otherwise.