Cayaba v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Bernardo S. Cayaba filed a claim for disability compensation against the Provincial Government of Isabela. Cayaba alleged that while employed as Clerk 1 at the Northern Isabela Emergency Hospital, he contracted rheumatoid arthritis and hypertension due to walking long distances and wading in water to get to work. His condition allegedly aggravated when he transferred to the respondent office as a toll clerk, exposed to cold, sunshine, and rain. He resigned on May 31, 1972, to apply for optional retirement under R.A. 1616, effective June 1, 1972. Procedural History: The Special Hearing Officer of Regional Office No. 11 dismissed the claim for lack of merit, finding that the claimant failed to present credible and substantial proof. The Workmen's Compensation Commission affirmed this decision. The Petition: The claimant, Bernardo Cayaba, filed a petition for review, arguing that the evidence presented was substantial and that the ailments were compensable.
Issue(s)
Whether the claimant presented substantial evidence to support his claim for disability compensation, and whether the claimant's illnesses, rheumatoid arthritis and hypertension, are compensable under the Workmen's Compensation Act. Whether the claimant is entitled to disability compensation for being forced to retire due to his illnesses.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The respondent Provincial Government of Isabela is ordered to pay the petitioner P6,000.00 as disability benefits, P600.00 as attorney's fees, reimburse medical expenses supported by receipts, and pay P61.00 as administrative fees.
Ratio Decidendi
On the issue of substantial evidence and compensability of illnesses: The Court found that the claimant adduced substantial evidence to show his claim was compensable. The claimant testified that his illnesses, rheumatoid arthritis and hypertension, were contracted and aggravated due to the nature of his work, which involved walking long distances, wading in water, and exposure to elements. Dr. Jose T. Cabrera corroborated the diagnosis of Essential hypertension and rheumatoid arthritis, stating he first treated the claimant on February 15, 1972. The respondent failed to present any evidence to controvert the claimant's evidence. The Court reiterated the disputable presumption that ailments supervening during employment are compensable, shifting the burden of proof to the employer to establish non-compensability. The claimant was relieved of the duty to prove causation due to this presumption, which was further supported by his evidence. The respondent did not adduce evidence to rebut this presumption or the claimant's evidence. On the entitlement to disability compensation for forced retirement: The Court held that an employee forced to retire ahead of schedule, not due to old age but principally because of a weakened bodily condition due to illness contracted in the course of employment, should be compensated for the inability to work during the remaining period before compulsory retirement. The claimant was forced to retire at 58 due to his illnesses, which incapacitated him. Had he not been forced to retire, he could have continued working for seven more years until age 65. Therefore, he is entitled to disability compensation for this period.
Main Doctrine
An employee forced to retire ahead of schedule due to illness contracted in the course of employment is entitled to disability compensation.