G.R. No. L-46575 August 31, 1988
JOSE LIMJOCO, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Reparations Commission) and SECRETARY OF LABOR (Compensation Appeals and Review Staff), respondents.

FACTS

Jose A. Limjoco, an Assistant Director of the Reparations Commission, retired in 1974. He filed a claim for disability compensation for nerve deafness and hyperopic astigmatism with presbyopia, which first manifested in 1970 while he was on an official flight to Cebu, suffering hearing loss upon reaching a certain altitude. A Workmen’s Compensation Commission referee awarded him permanent partial disability compensation based on a medical evaluation linking his illness to his employment. However, his separate claim for reimbursement of medical expenses incurred from 1970 to 1974 was dismissed by the Commission and later by the Acting Secretary of Labor. The dismissal was grounded on his alleged failure to submit to another physical examination and a finding of no causal link between his employment and the degenerative illness.

ISSUE

The primordial issue is whether Limjoco is entitled to claim reimbursement for his medical expenses under the Workmen’s Compensation Act.

RULING

Yes, the Supreme Court ruled in favor of Limjoco, reversing the Secretary of Labor’s decision. The legal logic centers on the applicable presumption of compensability under the old Workmen’s Compensation Act ( Act No. 3428 , as amended), which governed claims for illnesses occurring before January 1, 1975. Under this regime, once an illness or injury is shown to have occurred in the course of employment, it was legally presumed to have arisen out of or been aggravated by such employment. The burden to rebut this presumption by substantial evidence shifted to the employer.
The Court found that the public respondents failed to discharge this burden. The referee’s initial award of disability compensation was itself predicated on a medical report explicitly connecting Limjoco’s hearing loss to his work, specifically the incident during the official flight. This established the work-connection for the purpose of the claim. The subsequent demand for another physical examination to assess the claim for medical expenses was deemed unnecessary, as the compensability of the underlying disability had already been established. The Court emphasized the liberal interpretation mandated for labor legislation in favor of the worker. Since Limjoco was not afforded an opportunity to present receipts, the case was remanded to the competent commission to allow him to submit evidence supporting the monetary value of his medical expenses claim.