Barbas v. Victorias Milling Co., Inc.
REITERATIONFacts
The Antecedents: Eustaquio Barbas was employed by Victorias Milling Company from 1947 until his retirement on September 30, 1971, at the age of 55. He claimed that in 1969, while still employed, he contracted pulmonary tuberculosis (PTB). Procedural History: On August 22, 1972, Barbas filed a claim for disability benefits with the Workmen's Compensation Unit (WCU) at Bacolod City. The WCU, through Chief Referee Felicito Dr. Ciocon, found Barbas suffering from PTB Minimal with a 12% disability evaluation and awarded temporary partial disability benefits, along with necessary services, appliances, and medicines. The WCU also ordered the respondent to pay specific amounts for benefits, attorney's fees, and the Workmen's Compensation Fund. Barbas questioned the amount of the award and appealed to the Workmen's Compensation Commission (WCC). The WCC reversed the WCU's decision, dismissing the claim on the ground that Barbas failed to prove his PTB was contracted during his employment, noting that the x-ray showing PTB Minimal was taken after his retirement. The Petition: Barbas filed a petition for review with the Supreme Court, seeking to set aside the WCC's decision. He argued that the WCC erred in dismissing his claim, as he presented evidence, including an x-ray report, his affidavit detailing how he contracted the illness, a certificate of appreciation for his service, and a sick leave form, which collectively established that his PTB was contracted during his employment. He contended that his retirement was forced by his ailment and that he was entitled to disability benefits under the Workmen's Compensation Act.
Issue(s)
Whether the petitioner's claim for disability benefits due to pulmonary tuberculosis is compensable under the Workmen's Compensation Act. Whether the Workmen's Compensation Commission erred in reversing the decision of the Workmen's Compensation Unit at Bacolod City.
Ruling
The decision of the Workmen's Compensation Commission dismissing the claim for compensation is REVERSED and SET ASIDE. The decision rendered by the Workmen's Compensation Unit at Bacolod City is REINSTATED but MODIFIED. The private respondent is ordered to pay Eustaquio Barbas P6,000.00 as compensation, P600.00 to his counsel for attorney's fees, and P66.00 to the Ministry of Labor and Employment.
Ratio Decidendi
On Whether the petitioner's claim for disability benefits due to pulmonary tuberculosis is compensable under the Workmen's Compensation Act: The Supreme Court held that the petitioner's claim is compensable. The Court found that the petitioner presented sufficient evidence, including an x-ray report, his affidavit detailing the circumstances of contracting the illness, and a sick leave form dated November 17, 1969, which indicated he was confined and treated for PTB while still employed. The Court noted that the private respondent failed to rebut these material points. Furthermore, the Court applied the principle of presumption of compensability under the old Workmen's Compensation Act, stating that an illness contracted during employment is presumed to have arisen out of and in the course of employment. The Court also considered that the petitioner's retirement at age 55, before the usual retirement age, was likely forced upon him by his ailment, indicating a disability for work. On Whether the Workmen's Compensation Commission erred in reversing the decision of the Workmen's Compensation Unit at Bacolod City: The Supreme Court ruled that the WCC erred in reversing the WCU's decision. The WCC's dismissal was based on the erroneous impression that the petitioner's only evidence was an x-ray taken after retirement. However, the records clearly showed other evidence, such as the petitioner's affidavit and the sick leave form, establishing the onset of the illness during employment. The Court found that the WCU's initial award was supported by the evidence presented, and the WCC's reversal was not based on a correct appreciation of the facts. The Court reinstated the WCU's decision, albeit modifying the award to P6,000.00 under Section 14 of the Act, considering the petitioner's age and the equitable considerations, and acknowledging that full restoration to physical capacity for resumed employment was unlikely.
Main Doctrine
The Supreme Court reiterated that under the Workmen's Compensation Act, there is a presumption of compensability for illnesses contracted during employment. The burden of proof rests upon the employer to overcome this presumption by presenting substantial evidence to show that the illness did not arise during employment or that it is not compensable. The Court also emphasized that an employee's retirement due to illness, even if occurring after the initial diagnosis, can be considered as a consequence of the illness contracted during employment, leading to disability benefits.