Abcede v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: The petitioners are the parents of the late Romeo D. Abcede, who was employed as a delivery messenger by the Philippine Telegraph & Telephone Company (PTTC). Romeo D. Abcede died on December 3, 1974, at his residence due to "Asphyxial cardio-respiratory failure with marked congestion of lungs, heart, liver, stomach and pancreas." Five months prior to his death, he had reportedly complained of chest pain, difficulty breathing, and back pain. As Romeo D. Abcede died single, his dependent parents filed a claim for death compensation benefits. 2. Procedural History: The petitioners filed a claim for death compensation benefits with the Regional Office No. 4 of the Workmen's Compensation Commission (WCC). The private respondent, PTTC, opposed the claim, arguing that the illness was not work-connected. An Acting Referee of the WCC ruled in favor of the claimants, ordering PTTC to pay death compensation and burial expenses, based on the presumption that the illness was work-related and aggravated by employment. PTTC appealed this decision to the WCC, which reversed the Acting Referee's ruling, finding no evidence of a causal relationship between the employment and the death, nor proof that the alleged prior symptoms were medically treated or work-related. The petitioners then appealed the WCC's decision to the Supreme Court. 3. The Petition: The petitioners, as claimants, filed a petition for review on certiorari with the Supreme Court, which was treated as a special civil action. They contend that the WCC erred in failing to consider and apply Section 44 of Act 3428, as Amended, which establishes a presumption that a claim for compensation comes within the provisions of the Act in the absence of substantial evidence to the contrary. The petitioners argue that an illness contracted during employment is presumed to be work-connected, shifting the burden of proof to the employer to demonstrate otherwise. The Supreme Court ultimately ruled in favor of the appellants, reversing the WCC's decision and reinstating the award of death compensation benefits.
Issue(s)
Whether the illness that caused the death of Romeo D. Abcede is compensable under the Workmen's Compensation Act. Whether the Workmen's Compensation Commission erred in reversing the decision of the Acting Referee and denying the death compensation benefits.
Ruling
The Supreme Court reversed the decision of the Workmen's Compensation Commission, upholding the original award of death compensation benefits to the petitioners-claimants. The death compensation benefits were increased to P6,000.00, and PTTC was ordered to pay the prescribed fees to the Ministry of Labor and Employment.
Ratio Decidendi
On whether the illness that caused the death of Romeo D. Abcede is compensable under the Workmen's Compensation Act: The Court ruled in favor of the appellants-claimants, reiterating the principle that compensability of illness is presumed where the illness supervened during the employee's employment. This presumption is mandated by Section 44 of the Workmen's Compensation Act, which states that in the absence of substantial evidence to the contrary, it shall be presumed that the claim comes within the provisions of the Act. This legal presumption shifts the burden of proof to the employer to demonstrate that the employee's illness either did not arise out of the employment or was not aggravated by it. The Court noted that the employee died shortly after his last day of work and had previously complained of symptoms consistent with his ailment. The respondent employer failed to present substantial evidence to overcome the statutory presumption of compensability. Therefore, the illness was deemed service-connected. On whether the Workmen's Compensation Commission erred in reversing the decision of the Acting Referee and denying the death compensation benefits: The Court found that the WCC erred in its appreciation of the facts and its resolution of the claim. The WCC's reasoning that the claimants failed to prove the ailment was traceable to employment and that the employee was not treated by a physician for his symptoms was insufficient to overcome the presumption of compensability. The Court emphasized that the presumption under Section 44 of Act 3428 is a strong one, and the employer's failure to present substantial evidence to the contrary means the claim should have been upheld. The Court cited several previous rulings that support the principle that illness supervening during employment is presumed to be work-related or aggravated by it, and the burden of proof rests on the employer. Consequently, the WCC's reversal of the referee's award was deemed erroneous.
Main Doctrine
The presumption of compensability under Section 44 of the Workmen's Compensation Act shifts the burden of proof to the employer to show that the illness is not work-connected or that it was not aggravated by the employment. The employer failed to present substantial evidence to overcome this presumption.