Del Rosario v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Maria del Rosario filed a claim for death compensation against Luzon Stevedoring Corporation for the death of her son, Willie Rebite, alleging that Willie contracted pulmonary tuberculosis in 1966 as a result of his employment and that this illness led to his death on May 28, 1967. The respondent corporation denied liability. Procedural History: The Hearing Officer of Regional Office 4, Department of Labor, Manila, rendered an award in favor of the claimant. The Luzon Stevedoring Corporation appealed to the Workmen's Compensation Commission, which set aside the award, finding that the claimant failed to prove Willie Rebite's affliction with pulmonary tuberculosis at the time he stopped working, that the ailment caused his disability and death, and that filiation was not sufficiently proven. The Petition: This case is a petition for review of the decision of the Workmen's Compensation Commission.
Issue(s)
Whether the Workmen's Compensation Commission erred in setting aside the award granted to the claimant. Whether the claimant sufficiently proved her filiation to the deceased. Whether the illness of the deceased supervened during his employment and caused his death.
Ruling
The decision of the Workmen's Compensation Commission is set aside. Luzon Stevedoring Corporation is ordered to pay Maria del Rosario P4,160.00 as death benefit and P200.00 as burial expenses, plus attorney's fees and administrative fees.
Ratio Decidendi
On whether the Workmen's Compensation Commission erred in setting aside the award: The Supreme Court found that the Workmen's Compensation Commission erred. The Court noted that affidavits and a Social Security System death benefit adjudication showed Maria del Rosario to be the mother of the deceased Willie Rebite. Furthermore, the death certificate indicated Willie Rebite died of pulmonary tuberculosis, the same illness that supervened during his employment with Luzon Stevedoring Corporation. The illness having supervened during employment, there is a disputable presumption of compensability under Section 44 of the Workmen's Compensation Act. This presumption relieves the claimant of the burden to prove causation, shifting it to the employer to prove non-compensability. The claimant also presented evidence that the illness was a result of or aggravated by the employment, and no evidence rebutted this presumption or the presented evidence. On whether the claimant sufficiently proved her filiation to the deceased: The Court held that filiation was sufficiently proven. Affidavits were submitted to show that Maria del Rosario is the mother of the deceased Willie Rebite. Additionally, the death benefit adjudication from the Social Security System identified Maria R. Rebite as the mother and legitimate heir of Willie Rebite. This evidence, coupled with the presumption of legitimacy and the nature of death benefit claims, satisfied the requirement for proving filiation in this context. On whether the illness of the deceased supervened during his employment and caused his death: The Court affirmed that the illness, pulmonary tuberculosis, supervened during Willie Rebite's employment with Luzon Stevedoring Corporation and led to his death. The death certificate explicitly stated pulmonary tuberculosis as the cause of death. The fact that the illness manifested and progressed during his employment triggers the disputable presumption of compensability. The employer failed to present any evidence to overcome this presumption or to prove that the illness was not work-related or was aggravated by his employment. Therefore, the causal link between the employment and the illness, and subsequently death, was established by presumption and supported by evidence.
Main Doctrine
The illness of an employee that supervened during employment is disputably presumed to be compensable, shifting the burden of proof to the employer to establish that the illness is non-compensable. The claimant is relieved of the duty to prove causation when this presumption applies.