Berenguel v. Republic of the Philippines
REITERATIONFacts
The Antecedents: Petitioner Vicente Berenguel, a teacher with the Bureau of Public Schools since 1946, was confined for chronic and active pulmonary tuberculosis from November 16, 1957, to April 17, 1958. Before retiring at age 63 in 1969, he was treated for a minimal fibrotic lesion and underwent surgery for thyroid nodules. On March 31, 1975, he filed a claim for disability benefits for various illnesses, including indirect inguinal hernia, varicose veins, pulmonary tuberculosis, atelectasis, and chronic cholecystitis. Procedural History: The Acting Referee granted disability benefits for the period of his inability to work due to pulmonary tuberculosis (July 16, 1969, to October 25, 1969) and reimbursed medical expenses. The Workmen's Compensation Commission (WCC) reversed this, dismissing the claim, stating that a chest X-ray taken in 1975 did not show pulmonary tuberculosis and that medical expense receipts were dated after retirement. A motion for reconsideration was denied. The Petition: Petitioner sought review, arguing that his pulmonary tuberculosis was contracted during employment and that the WCC erred in reversing the referee's findings on compensability and medical expense reimbursement.
Issue(s)
Whether the Workmen's Compensation Commission erred in reversing the findings of the referee that the petitioner's pulmonary tuberculosis (PTB) is causally related to his employment and other sicknesses incurred in the course of employment. Whether the Workmen's Compensation Commission erred in reversing the grant of reimbursement of medical expenses by the referee.
Ruling
The decision of the Workmen's Compensation Commission is REVERSED. The original award granting disability benefits and medical expense reimbursement to the petitioner is reinstated, with disability benefits increased to P6,000.00 and respondent ordered to pay P61.00 in fees to the Ministry of Labor and Employment, plus P600.00 for attorney's fees.
Ratio Decidendi
On the first assigned error (compensability of PTB): The Court reiterated the well-settled rule that once an illness is shown to have supervened during employment, there is a rebuttable presumption that it arose out of or was aggravated by employment. The burden to disprove this causal relation rests on the employer. The petitioner established that his pulmonary tuberculosis was contracted during his employment in 1957, and the respondent failed to present substantial evidence to overcome the presumption of compensability. The contention that public school teachers were not covered by the Workmen's Compensation Act in 1957 is untenable, as the fact of contracting the illness during employment is established, and the law's coverage at the time of contracting does not negate the employer's obligation if the illness persisted and became disabling during the period of employment or retirement. The Court also noted that the petitioner was still sick and not allowed to return to work upon his retirement, and was required to retire in the interest of public health, indicating disability rather than voluntary retirement. On the second assigned error (medical expense reimbursement): The Court found merit in the petitioner's contention that the findings of fact of the Workmen's Compensation Unit should be upheld unless there are strong reasons to the contrary. The fact that medical expenses were incurred after retirement is not decisive, as the test for compensability under the old Workmen's Compensation Law is probability, not certainty. Since the petitioner's illness was established as compensable and work-related, the reimbursement of medical expenses incurred in relation to that illness should be upheld. The Court also affirmed that an X-ray result is not an indispensable prerequisite for compensation, and the referee's evaluation of medical benefits should be respected.
Main Doctrine
The presumption of compensability under the Workmen's Compensation Act, once an illness is shown to have arisen in the course of employment, shifts the burden to the employer to disprove the causal relation. An X-ray result is not an indispensable prerequisite for compensation, and medical expenses incurred after retirement are compensable if the illness is work-related.