Better Buildings, Inc. v. Pucan
REITERATIONFacts
The Antecedents: Rogelio Fernando, employed as a janitor and later maintenance supervisor by Better Buildings, Inc., filed a claim for workmen's compensation benefits due to an illness diagnosed as Hansen's Disease Lepromatous positive with claw hands on both. Fernando alleged that his illness, which reappeared and worsened during his employment, was a result of his duties, which included cleaning funeral parlors where he was exposed to germs and bacteria. Procedural History: Fernando's claim for compensation benefits was initially granted by a letter-award from Regional Office No. 4 of the Department of Labor. Better Buildings, Inc. controverted the claim, asserting the ailment did not arise from or was aggravated by employment. The Workmen's Compensation Commission affirmed the letter-award, leading to the present petition for review. The Petition: Better Buildings, Inc. petitions this Court for review, arguing that Hansen's Disease is not an occupational disease and is not among those held compensable. The petitioner also contended that the evidence did not conclusively prove the ailment was caused or aggravated by Fernando's employment. The Court, however, found the petition without merit, citing established jurisprudence that under the former Workmen's Compensation Act, the burden of proof to refute causation or aggravation by employment rests with the employer, and that probability, not absolute certainty, is the standard of proof in compensation proceedings.
Issue(s)
Whether the illness of Rogelio Fernando, Hansen's Disease, was contracted or aggravated in the course of his employment with petitioner. Whether the petitioner sufficiently discharged its burden of proof to refute the presumption that the illness is compensable under the Workmen's Compensation Act. Whether Hansen's Disease is a compensable ailment under the Workmen's Compensation Act.
Ruling
The petition for review is denied for lack of merit. The decision of the Workmen's Compensation Commission is affirmed, with modifications ordering the petitioner to pay disability compensation benefits, attorney's fees, and administrative costs.
Ratio Decidendi
On whether the illness was contracted or aggravated in the course of employment: The Court found that while Fernando had Hansen's Disease in 1963, there was evidence he was declared negative and released from treatment in 1969. This indicated his illness was either non-existent or dormant prior to his 1971 employment. The Court reasoned that its reappearance and aggravation could be traced to his weakened resistance due to exposure to germs, bacteria, and other stresses while performing his duties as a janitor in funeral parlors. The nature of his work, involving contact with cadavers and disposal of waste, presented conditions that could lead to the contraction or aggravation of such a disease. The Court emphasized that under the former Workmen's Compensation Act, the presumption is that an illness contracted or aggravated during employment is compensable. On the employer's burden of proof: The Court held that under the former Workmen's Compensation Act, the burden of refuting the presumption that an ailment was contracted or aggravated in the course of employment rests upon the employer. The petitioner relied on a physician's report which stated "Maybe" to questions regarding whether the injury or illness was caused by employment, the result of the nature of employment, or aggravated by employment. The Court found this equivocal statement insufficient to discharge the petitioner's burden of proof. It reiterated that strict rules of evidence are not applicable in compensation claims, and probability, not absolute certainty, is the test of proof. On whether Hansen's Disease is compensable: The Court affirmed that Hansen's Disease is a compensable ailment. Citing previous rulings, the Court stated that the contention that the disease is not compensable is without merit. It acknowledged expert testimony indicating that leprosy is a systemic disease whose development can be influenced by factors such as exposure to sudden environmental changes and lessened body resistance. The Court further reinforced this by referencing the presumption under Section 44 of the Workmen's Compensation Act, which presumes that a claim comes within the Act's provisions in the absence of substantial evidence to the contrary. The cause of the ailment is immaterial; what is important is that it occurred or was aggravated in the course of employment and disabled the workman.
Main Doctrine
Under the former Workmen's Compensation Act, an illness is compensable if it was contracted or aggravated in the course of employment, and the burden of proof to refute this presumption lies with the employer. Probability, not absolute certainty, is the test of proof in compensation proceedings.