Pros v. Republic
REITERATIONFacts
The Antecedents: Petitioner Isias Pros was employed as a telephone lineman by the Republic of the Philippines (Bureau of Telecommunications) from July 1951 until November 1973. During his employment, he suffered multiple strokes: one in June 1965, another in August 1965, a third in December 1966, and a fourth in February 1973. These ailments, diagnosed as hypertension, rheumatism, arthritis, and fainting spells, led him to spend P1,500.00 for medical expenses and eventually retire from service. Procedural History: Petitioner filed a claim for compensation benefits due to disability caused by his ailments. The respondent Republic failed to controvert the claim. The Acting Labor Referee conducted an ex-parte hearing and, after requiring petitioner to submit to a physical examination by the Compensation Rating Medical Officer, dismissed the claim based on the latter's report finding the disability to be negative. A request to cross-examine the medical officer was denied. The Workmen's Compensation Commission affirmed the dismissal. The Petition: Petitioner sought a review of the Commission's decision, arguing that his illness was compensable under the Workmen's Compensation Act.
Issue(s)
Whether petitioner's illness is compensable under the Workmen's Compensation Act. Whether the denial of the request to cross-examine the Compensation Rating Medical Officer was proper. Whether petitioner is entitled to disability compensation and reimbursement of medical expenses.
Ruling
The decision of the respondent Commission is reversed and set aside. The respondent Republic (Bureau of Telecommunications) is ordered to pay petitioner P6,000.00 as disability compensation and P1,500.00 as reimbursement for medical expenses.
Ratio Decidendi
On the compensability of petitioner's illness: The Court held that the petitioner, a lineman for twenty-four years, was frequently exposed to the elements, which led to his hypertension and subsequent strokes. Dr. Jose Llanto testified that the petitioner's ailment was due to his exposure to the elements and had permanently and totally disabled him for labor. The Court emphasized the well-settled rule that once an illness supervened in the course of employment, a rebuttable presumption arises that it arose out of or was aggravated by such employment. The burden to overthrow this presumption shifts to the employer. In this case, the respondent Republic failed to controvert the claim, which is considered fatal to any defense and an admission that the claim is compensable. Therefore, the illness is deemed compensable under Section 2 of the Workmen's Compensation Act. On the denial of the cross-examination: While Section 3 of Department Order No. 3 of the Secretary of Labor allows the Unit to depend on the medical opinion of the Compensation Rating Medical Officer, the Court found it more prudent to give greater weight to the petitioner's evidence of suffering four strokes while in the performance of his duties, especially when contrasted with the negative report of the Compensation Rating Medical Officer. The Court's inclination to give more weight to the petitioner's evidence suggests that the denial of cross-examination, while potentially permissible under the Department Order, did not override the substantial evidence presented by the petitioner regarding his condition and its relation to his employment. On entitlement to compensation and reimbursement: Given that the illness was deemed compensable and the petitioner's disability was permanent and total, he is entitled to disability compensation. Pursuant to Section 14 of the Workmen's Compensation Act, he should be granted P6,000.00 as compensation. Additionally, under Section 13 of the same Act, he is entitled to reimbursement of his medical expenses amounting to P1,500.00, as evidenced by the exhibits presented.
Main Doctrine
Once an illness supervened during employment, a rebuttable presumption arises that it arose out of or was aggravated by such employment, and the burden to overthrow this presumption shifts to the employer. Failure to controvert the claim is fatal to any defense and constitutes an admission that the claim is compensable.