Cadiente v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Canuto B. Cadiente filed a claim for disability compensation benefits against the Republic of the Philippines (Rice and Corn Administration, later National Grains Authority) for pulmonary tuberculosis allegedly contracted or aggravated by his employment. Cadiente was employed from September 20, 1954, with various periods of lay-off and reinstatement, eventually serving as a Security Guard. He began experiencing chest and back pains with fever in April 1968, and was diagnosed with pulmonary tuberculosis by the company physician and the municipal health officer. Due to his illness, he stopped working on May 20, 1970, and was subsequently retired from the service due to illness. Procedural History: The Acting Referee of Regional Office No. 4, Department of Labor, found the facts established and rendered a decision in favor of the claimant, ordering the National Grains Authority to pay disability compensation benefits, attorney's fees, and decision fees. The Workmen's Compensation Commission reversed this decision, absolving the National Grains Authority on the ground that it was not shown that the claimant left the service by reason of his illness. The Petition: The claimant, Canuto Cadiente, filed a petition to review the decision of the Workmen's Compensation Commission.
Issue(s)
Whether the Workmen's Compensation Commission erred in reversing the decision of the Acting Referee regarding the claimant's retirement due to illness. Whether the claimant is entitled to disability compensation benefits for pulmonary tuberculosis, given the presumption that the ailment arose out of employment.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The National Grains Authority is ordered to pay Canuto B. Cadiente P6,000.00 as disability compensation benefits and P600.00 as attorney's fees, and P61.00 as administrative fee.
Ratio Decidendi
On the reversal by the Workmen's Compensation Commission: The Court found that the Commission's basis for absolving the National Grains Authority – that it was not shown the claimant left service due to illness – was contrary to the factual finding of the Acting Referee that the claimant was retired due to illness. The presumption of compensability, which was not rebutted, supported the claim. The Court's setting aside of the Commission's decision is a direct consequence of the application of the presumption and the factual findings of the referee. On the entitlement to disability compensation benefits: The Court found that the Workmen's Compensation Commission erred in reversing the Acting Referee's decision. The Acting Referee had established that the claimant was retired from the service due to his illness on May 20, 1970. There was no showing that the claimant suffered from any ailment when he was first employed in 1954. The illness causing his disability was reasonably connected with his employment, and it supervened during his employment. The Court reiterated the rebuttable presumption that an ailment arose out of employment, as established in cases like Delgado brothers, Inc. vs. Workmen's Compensation Commission and Justiniano vs. Workmen's Compensation Commission, and Section 44 of the Workmen's Compensation Act. This presumption was not rebutted by the respondent. Therefore, the claimant is entitled to disability compensation benefits.
Main Doctrine
The presumption that an illness contracted during employment arose out of said employment is rebuttable and has not been rebutted in this case, entitling the claimant to disability compensation benefits.