Cabreira v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Celso A. Cabreira, an employee of the General Auditing Office, filed a claim for disability compensation due to an illness requiring prostate gland surgery, which he alleged was caused by his employment. He stopped working on May 4, 1973, due to "Benign Prostatic Hyperthrophy, urinary tract infection and hyperurecimia" and resumed work on June 18, 1973. Procedural History: The Acting Referee of Regional Office No. 4 awarded disability compensation and reimbursement of medical expenses. The Republic of the Philippines (General Auditing Office) appealed to the Workmen's Compensation Commission (WCC). The WCC reversed the decision of the Regional Office, dismissing the case for lack of merit, holding that the illness was not due to employment. The Petition: Cabreira filed a petition for review of the WCC decision.
Issue(s)
Whether the illness of the petitioner is compensable under the Workmen's Compensation Act. Whether the illness was aggravated by the nature of the petitioner's work.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The Republic of the Philippines (General Auditing Office) is ordered to pay the petitioner P420.36 as temporary total disability benefit, P3,544.46 as reimbursement for medical expenses, P42.00 as attorney's fees, and P61.00 as administrative fee.
Ratio Decidendi
On whether the illness of the petitioner is compensable under the Workmen's Compensation Act: The Court held that the illness of the petitioner supervened during his employment with the General Auditing Office. 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 establish that the illness is not compensable. The employer failed to rebut this presumption. On whether the illness was aggravated by the nature of the petitioner's work: The petitioner presented evidence that his illness was a result of continuously holding his urination because his work prevented him from answering the call of nature regularly. While the employment might not have directly caused the prostatic enlargement, the Court found that the illness was aggravated by the nature of the petitioner's work. This aggravation, coupled with the presumption of compensability, supports the claim. The employer did not present evidence to controvert this claim of aggravation or the presumption of compensability. Therefore, the claim is deemed compensable.
Main Doctrine
The illness of an employee is presumed to have arisen out of employment if it supervened during said employment. The employer bears the burden of proving that the illness is not compensable. Furthermore, an illness may be compensable if it was aggravated by the nature of the work, even if not directly caused by it.