Vda. de Cardiente v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Bonifacio Cardiente, a member of the Bacolod Police Department, was diagnosed with "Common Bile Duct Obstruction" in 1964, requiring surgery. He returned to work but later underwent another operation for cirrhosis of the liver in December 1974. He died on December 27, 1974. Prior to his death, he had filed a claim for disability benefits based on his bile duct obstruction. Procedural History: The claim for death benefits filed by his widow, Estelita Vda. de Cardiente, was dismissed by the hearing officer of the Workmen's Compensation Unit of Bacolod City for lack of merit, finding no causal relation between the illness (ascariasis leading to cirrhosis) and the deceased's work as a policeman. The Workmen's Compensation Commission affirmed this decision, stating that while the illness supervened during employment, it was not sufficiently traceable to the employment. The Petition: The petition assails the decision, arguing that the Commission erred in holding that the illness had no causal link to the employment and in disregarding the possibility that the illness was aggravated by his work.
Issue(s)
Whether the death of Bonifacio Cardiente due to cirrhosis of the liver is compensable under the Workmen's Compensation Act, given the presumption of causal connection and the nature of his employment as a police officer.
Ruling
The decision of the respondent Workmen's Compensation Commission is REVERSED and SET ASIDE. The respondent City of Bacolod is ordered to pay death benefits, burial expenses, attorney's fees, and administrative fees.
Ratio Decidendi
On Issue 1: The Supreme Court ruled in favor of compensability, emphasizing that under Section 2 of the Workmen's Compensation Act (Act No. 3428), diseases are compensable if they are directly caused by employment, aggravated by it, or result from the nature of the employment. The Court noted that Cardiente's bile duct obstruction, which eventually led to cirrhosis of the liver, pre-existed and supervened during his tenure as a police officer. Applying the doctrine in Arianza v. Workmen's Compensation Commission, the Court held that the legal presumption of causal connection under Section 44 of the Act remains unrebutted by the employer; although the work might not be the direct cause, the working conditions—specifically the environmental risks associated with police surveillance work—aggravated the illness. The Court further cited Abana v. Quisumbing, stating that employment need not be the sole factor in the development of the disease, as it is sufficient that the work contributed even in a small degree. Furthermore, following Villavieja v. Marinduque Mining and Industrial Corporation, the Court reiterated that when an illness supervenes during employment, the burden of proof shifts to the employer to show non-causation. Since the City of Bacolod failed to present substantial evidence to rebut this presumption, the mere medical opinions of doctors attempting to disconnect the ailment from the employment cannot prevail over the statutory mandate of compensability.
Main Doctrine
Under the former Workmen's Compensation Act, as amended, it is presumed that an illness which supervened during employment arose out of or was at least aggravated by said employment, shifting the burden of proof to the employer to rebut this presumption. It is not required that employment be the sole factor in the aggravation of an illness; it is sufficient that it contributed even in a small degree.