Garcia v. Compensation Appeals and Review Staff
REITERATIONFacts
The Antecedents: Petitioner Eufracina Garcia was a classroom teacher from November 7, 1937, until her retirement on February 16, 1975. She became frequently absent starting September 16, 1973, due to pulmonary tuberculosis minimal (PTB) and arteriosclerotic heart disease, which worsened over time. Her doctor advised against strenuous exertion on March 6, 1974, leading to her resignation on February 16, 1975. Procedural History: Petitioner filed a claim for disability compensation, alleging her illnesses were work-connected and aggravated by her employment. The Acting Referee found the disability work-connected and awarded partial disability compensation. The Workmen's Compensation Commission reversed this, holding the illnesses were not work-connected. The Secretary of Labor affirmed the Commission's decision. The Petition: Petitioner sought review of the Commission's decision, contending she was entitled to the maximum compensation benefit of P6,000.00.
Issue(s)
Whether the petitioner's illnesses, pulmonary tuberculosis and arteriosclerotic heart disease, are work-connected and compensable. Whether the petitioner is entitled to the maximum disability compensation benefit of P6,000.00.
Ruling
The decision of the respondent Workmen's Compensation Commission is SET ASIDE. The respondent Bureau of Public Schools is ordered to pay claimant Eufracina Garcia the sum of Six Thousand Pesos (P6,000.00) as disability compensation, and Six Hundred Pesos (P600.00) as attorney's fees, and to pay an administrative fee of Sixty-One Pesos (P61.00).
Ratio Decidendi
On whether the petitioner's illnesses are work-connected and compensable: The Court reiterated that it is not required that employment be the sole factor in the development or aggravation of an illness; it is sufficient that it contributed even in a small degree. Under Section 44 of the Workmen's Compensation Act, as amended, an illness supervening during employment is presumed to have arisen from or been aggravated by it, and the employer bears the burden of overcoming this presumption. The Court noted that arteriosclerosis, like other heart diseases, is progressive and its symptoms may appear suddenly after a long build-up. It is well-settled that heart diseases are compensable in the Philippines. Furthermore, pulmonary tuberculosis (PTB) has been held to be service-connected and compensable. The facts showed that the petitioner was in good health when she started teaching and felt the symptoms of her ailments during her employment, which ultimately forced her to resign. On whether the petitioner is entitled to the maximum disability compensation benefit of P6,000.00: The Court held that the petitioner was entitled to full compensation, not merely partial. When an employee is forced to retire ahead of schedule due to illness contracted in the course of employment, she should be compensated for her inability to work during the remaining days before her scheduled retirement. Denying permanent total disability benefits to an employee forced to retire due to illness contracted in the course of employment would render meaningless the social justice precept guaranteed by the Constitution. The petitioner's 38 years of dedicated service as a school teacher, coupled with her forced retirement due to work-aggravated illnesses, warranted the maximum compensation.
Main Doctrine
An illness that supervened during employment is presumed to have arisen from or at least been aggravated by such employment, and the employer must overcome this presumption. Heart diseases and pulmonary tuberculosis are compensable, and an employee forced to retire due to illness contracted in the course of employment is entitled to full disability benefits.