Caparas v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Jose B. Caparas was employed as a salesman-driver by Seven Up Bottling Company of the Philippines. In August 1966, he suffered dizziness, severe headaches, and heart palpitations, diagnosed as "Hyperthyroid heart Disease and Rheumatoid Arthritis." He verbally notified his supervisor. Shortly thereafter, the company sold its plant, leading to its closure and petitioner's inability to be rehired due to his illness. Procedural History: Petitioner filed a claim for compensation benefits under the Workmen's Compensation Act. The Acting Referee dismissed the claim outright without a hearing, deeming the illness non-compensable. The Workmen's Compensation Commission affirmed this decision, considering the illness non-occupational. The Petition: Petitioner seeks review of the Commission's decision, alleging grave abuse of discretion and denial of due process for the lack of hearing and evidence presentation. He contends his illness was aggravated by his employment and is compensable.
Issue(s)
Whether the Workmen's Compensation Commission committed grave abuse of discretion and denied petitioner due process by dismissing his claim without a hearing. Whether petitioner's illness, "Hyperthyroid heart Disease and Rheumatoid Arthritis," is compensable under the Workmen's Compensation Act. Whether petitioner is entitled to compensation benefits for permanent total disability and reimbursement of medical expenses.
Ruling
The Supreme Court set aside the decision of the respondent Commission and rendered a new decision ordering the private respondent to pay petitioner P6,000.00 as compensation benefits for permanent total disability, P356.00 for medical and hospital expenses, and attorney's fees equivalent to ten percent (10%) of the total award.
Ratio Decidendi
On the issue of grave abuse of discretion and denial of due process: The Court found that the Acting Referee and the respondent Commission acted with grave abuse of discretion and contrary to law in denying the claim without a hearing. Department Order No. 3, implementing Letter of Instruction No. 190, authorized the receipt of affidavits concerning the circumstances of illness, which could be rebutted by counter-affidavits. Petitioner submitted his claim detailing the circumstances of his illness and a Physician's Report indicating aggravation due to employment. The respondent employer did not submit any counter-affidavit to rebut these claims, nor did the Acting Referee require them to do so. The outright dismissal without affording petitioner the opportunity to present evidence or requiring the employer to submit counter-affidavits constituted a denial of due process. On the compensability of the illness: The Court held that the illness of the petitioner did supervene in the course of his employment. It is a consistent ruling 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 the employment. The burden then shifts to the employer to overcome this presumption. In this case, the Physician's Report explicitly stated that the ailment was aggravated by employment. The private respondent failed to present any evidence, such as a counter-affidavit, to rebut this presumption. Therefore, the illness is deemed compensable. On entitlement to compensation benefits: Pursuant to the Physician's Report, the petitioner's sickness resulted in permanent total disability for labor. The fact that he could not be rehired by the company after the unfair labor practice settlement due to his illness further supports this finding. Consequently, under Section 14 of the Workmen's Compensation Act, he is entitled to compensation benefits for permanent total disability. Additionally, under Section 13 of the same Act, he is entitled to reimbursement for medical and hospital expenses incurred, as indicated in his claim.
Main Doctrine
An illness that supervenes in the course of employment is presumed to have arisen out of or been aggravated by such employment, shifting the burden to the employer to rebut this presumption. Failure to do so entitles the employee to compensation benefits.