Ayuso v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Leopoldo Ayuso was employed by White Ways, Inc. as a laborer from 1970 to August 31, 1972, earning P9.00 daily, performing menial tasks such as cleaning toilets and making repairs. Prior to this, from 1965 to 1970, he worked for "Better Buildings," a sister company, where he already suffered from a coronary disease and was confined twice in the Philippine General Hospital (PGH) in 1967 and 1968. In 1970, he complained of a persistent cough. On November 12, 1972, while employed with White Ways, Inc., he was again confined in PGH, where his illness was diagnosed as pulmonable, secondary to primary lung disease with minimal PTB, and an enlarged heart. Doctors opined that his lung ailment was aggravated by his work and certified that he was unfit for strenuous work, with a Physician's Report indicating his disability was "total." 2. Procedural History: Leopoldo Ayuso filed a claim for compensation benefits on May 16, 1973. While the claim was pending, he died on August 15, 1975, and his wife, Apolonia Bautista, was substituted as petitioner. The respondent Workmen's Compensation Commission denied the claim, ruling that petitioner failed to establish that the illness was contracted during employment and that it incapacitated him for labor before his separation, which was due to the business closing. 3. The Petition: The petitioner seeks a review of the decision of the respondent Commission.
Issue(s)
Whether the petitioner's illness supervened in the course of employment and was aggravated by his work. Whether the petitioner was incapacitated for labor due to his illness before his separation from employment. Whether the closing of the business of the private respondent excuses it from liability for compensation benefits.
Ruling
The judgment of the respondent Commission is set aside. The private respondent is ordered to pay the petitioner compensation benefits for permanent and total disability in the amount of P6,000.00, plus attorney's fees.
Ratio Decidendi
On whether the petitioner's illness supervened in the course of employment and was aggravated by his work: The Court found that the deceased had a history of lung ailment and cardiac issues even before his employment with White Ways, Inc., having been confined twice in PGH for such conditions while working for a sister company. His persistent cough in 1970 further indicated a pre-existing condition. When White Ways, Inc. employed him despite this known medical history, it assumed the risk of further aggravation of his illness. Therefore, it cannot be denied that the illness supervened in the course of his employment with the private respondent. The Court reiterated the established principle 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 said employment. This presumption shifts the burden of proof to the employer to present substantial evidence to the contrary. The private respondent failed to offer any proof to rebut this presumption. On whether the petitioner was incapacitated for labor due to his illness before his separation from employment: The Court noted that the Physician's Report clearly stated the deceased's disability was "total" and that he was not fit to do strenuous work. The fact that he continued to work, even if it was the same type of job, could be attributed to his need to earn for his family. The critical factor is not whether he could still work by forcing himself, but whether his physical condition permitted him to perform his assigned duties normally. Given the physician's certification of total disability, he should be entitled to compensation benefits under Section 14 of the Workmen's Compensation Act. The nature of his work, which involved cleaning toilets and making repairs, was strenuous and likely aggravated his condition. On whether the closing of the business excuses the employer from liability: The Court held that the expiration of the private respondent's license to operate and the subsequent closing of its business do not absolve it from its liability to provide compensation benefits to an employee who became ill during the course of employment. The closing of the business cannot prejudice the rights of employees to recover what is due to them under the law. The law mandates compensation for illnesses arising out of or aggravated by employment, regardless of the employer's business status.
Main Doctrine
Once an illness is shown to have supervened in the course of employment, there is a rebuttable presumption that said illness arose out of or was aggravated in the course of employment, shifting the burden to the employer to prove otherwise. The closing of a business does not excuse the employer from liability for compensation benefits.