Cabalquinto v. Republic of the Philippines
REITERATIONFacts
The Antecedents: Petronila T. Cabalquinto, a public school teacher and principal, filed a claim for compensation due to chronic muscular rheumatism, hypertension, and weak heart, ailments she alleged were contracted or aggravated during her employment with the Bureau of Public Schools. She began her service in 1932 and continued until her retirement in 1973, during which time she held various teaching and administrative positions, including Principal I. Her duties involved significant responsibilities, including supervision, planning, fundraising, and extensive community engagement, often requiring long hours and exposure to adverse conditions. Procedural History: Cabalquinto filed her claim with the Department of Labor's Regional Office No. 4 on March 12, 1974. Despite the respondent failing to file a controversion within the reglementary period, the case proceeded to a hearing. An Acting Referee rendered a decision on August 28, 1974, awarding the claimant P6,000.00 in disability compensation, P300.00 in attorney's fees, and P61.00 in administrative fees. The respondent, Republic of the Philippines (Bureau of Public Schools), appealed this decision to the Workmen's Compensation Commission. The Commission reversed the Acting Referee's decision, absolving the respondent of liability on the grounds that the claimant had not been incapacitated for labor prior to her retirement. The Petition: This petition seeks a review of the Workmen's Compensation Commission's decision. The petitioner argues that the respondent's appeal to the Commission was filed beyond the statutory period, rendering the Acting Referee's decision final and executory. Consequently, the petitioner contends that the Commission erred in reversing the initial award and absolving the respondent, as the appeal should have been dismissed on procedural grounds. The petitioner seeks to reinstate the decision of the Acting Referee.
Issue(s)
Whether the respondent's appeal to the Workmen's Compensation Commission was filed beyond the reglementary period. Whether the claimant's ailments were compensable under the Workmen's Compensation Act.
Ruling
The decision of the Workmen's Compensation Commission is set aside. The Republic of the Philippines (Bureau of Public Schools) is ordered to pay the petitioner P6,000.00 as disability compensation benefit and P600.00 as attorney's fees, and to pay the successor of the Workmen's Compensation Commission P61.00 as administrative fees.
Ratio Decidendi
On the issue of the timeliness of the appeal: The Court deemed it unnecessary to pass upon the timeliness of the respondent's appeal to the Workmen's Compensation Commission, given its resolution of the substantive issue of compensability in favor of the petitioner. On the issue of the compensability of the claimant's ailments: The Court held that the petitioner's ailments, chronic muscular rheumatism and hypertension, supervened during her employment with the respondent. Under Section 44 of the Workmen's Compensation Act, there is a disputable presumption that claims for illness contracted during employment are compensable. This presumption shifts the burden of proof to the employer to establish that the illness is non-compensable. The Court found that the respondent failed to overcome this presumption. The evidence adduced by the petitioner, including the medical opinion of Dr. Cadena, indicated that her duties as a principal-teacher, with their inherent burdens and extra-curricular activities, aggravated her physical condition, leading to lack of rest and sleep and exposure to bad weather. These factors contributed to her ailments and eventual disability. The respondent did not present sufficient evidence to rebut the presumption of compensability or to prove that the ailments were entirely unrelated to her employment. The Court also noted that the petitioner was in good health when she entered the employment in 1932 and only experienced symptoms in 1971, further supporting the presumption that the illness arose out of her employment.
Main Doctrine
The employer bears the burden of proof to overcome the disputable presumption that an illness supervening during employment is compensable, and this presumption is not overcome by the employer's failure to file a controversion within the reglementary period.