Barcenas v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Sergio C. Barcenas, a Senior Commercial Agent for the Bureau of Standards, became ill in November 1972 with diabetes mellitus and hypertensive vascular disease while on an inspection trip. This illness led to a leave of absence and his subsequent retirement in April 1973 at the age of sixty-one. He filed a claim for disability benefits under the Workmen's Compensation Act. Tragically, he passed away on March 13, 1974, due to acute myocardial infarction and diabetes mellitus, while his claim was still pending. His wife, Ana C. Barcenas, then filed a claim for death benefits. Procedural History: Initially, Acting Referee Dionisio T. Tabucanon ruled in favor of the petitioner on February 18, 1975, ordering the Bureau of Standards to pay disability benefits, attorney's fees, and administrative fees. The Republic, through the Solicitor General, filed a motion for reconsideration, which was denied. The case records were then elevated to the Workmen's Compensation Commission. On December 12, 1975, the Commission reversed the Acting Referee's decision, dismissing the claim. The Commission reasoned that diabetes mellitus could not be considered work-related as it is attributed to an individual's eating and drinking habits. The Petition: Disagreeing with the Commission's decision, the petitioner, Ana C. Barcenas, filed the instant petition. The Supreme Court, after receiving comments from the Solicitor General and the Commission, resolved to treat the petition as a special civil action and requested the submission of memoranda. The Court's resolution to grant the petition is based on its prior rulings that diabetes mellitus, hypertension, and myocardial infarction are compensable under the Workmen's Compensation Act. The Court emphasized that the employment need not be the sole cause, but only a contributing factor, and invoked the legal presumption of compensability, which the respondent failed to rebut.
Issue(s)
Whether diabetes mellitus, hypertension, and myocardial infarction are compensable under the Workmen's Compensation Act. Whether the presumption of compensability under the Workmen's Compensation Act was rebutted by the employer.
Ruling
The decision of the Workmen's Compensation Commission is SET ASIDE and the decision of Acting Referee Tabucanon is affirmed in toto. The claim for death benefits is compensable.
Ratio Decidendi
On whether diabetes mellitus, hypertension, and myocardial infarction are compensable under the Workmen's Compensation Act: The Court reiterated its previous rulings that these ailments are compensable under the Workmen's Compensation Act. The Court cited Flores v. Workmen's Compensation Commission and Sevilla v. Workmen's Compensation Commission, which held that diabetes mellitus and hypertension are compensable. The Court emphasized that it is not required for the employment to be the sole factor in the aggravation of an illness; it is sufficient that the employment contributed, even in a small degree. The exact medical cause of the illness is not significant, and the law presumes that illnesses supervening during employment either arose out of, or were aggravated by, the employment. On whether the presumption of compensability under the Workmen's Compensation Act was rebutted by the employer: The Court held that under Section 44 of the Workmen's Compensation Act, as amended, there is a legal presumption that illnesses which supervened during employment either arose out of, or were at least aggravated by, the employment. This presumption shifts the burden of proof to the employer to show that the illness is not compensable. In the instant case, the respondent Bureau of Standards failed to rebut this legal presumption. The Court also noted that even under the more restrictive provisions of the Labor Code, cardiovascular disease, including myocardial infarction, is listed as a work-related disease.
Main Doctrine
Ailments such as diabetes mellitus, hypertension, and myocardial infarction are compensable under the Workmen's Compensation Act, and the presumption of compensability shifts the burden of proof to the employer to rebut this presumption.