G.R. No. L-46102 April 15, 1988
BENJAMIN SEGOVIA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Posts), WORKMEN’S COMPENSATION COMMISSION, et al., respondents.

FACTS

Petitioner Benjamin Segovia was employed as a clerk by the Bureau of Posts in July 1971, initially in excellent health. In October 1972, he began experiencing chest pains, severe coughing, and fever, leading to a diagnosis of pulmonary tuberculosis (PTB) and subsequent medical treatment. By December 1972, he also complained of headaches and dizziness, diagnosed as severe hypertension, for which he underwent further treatment. For these illnesses, Segovia filed a claim for disability benefits with the Workmen’s Compensation Unit, which found the sicknesses compensable and ordered the Bureau of Posts to pay benefits on August 28, 1974.
The Bureau of Posts filed a Motion to Modify Decision on February 19, 1976, which the regional office denied but elevated the records to the Workmen’s Compensation Commission (WCC) for review. The WCC reversed the regional office’s decision, declaring the illnesses non-compensable. The Commission based its ruling on the claimant’s alleged failure to show he went on sick leave and the absence of an X-ray report to substantiate the PTB diagnosis, stating it was unfair to grant the claim without such documentary support.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing the petitioner’s claim for disability benefits based on pulmonary tuberculosis and hypertension.

RULING

Yes. The Supreme Court reversed the WCC decision, reinstating the award of compensation benefits. The legal logic proceeds from the application of the old Workmen’s Compensation Act as a social legislation to be construed liberally in favor of the employee. First, the Court resolved that tuberculosis is considered an occupational disease if it arose in the course of or was aggravated by employment. Here, Segovia’s clerical duties involving sorting, filing, and verifying documents contributed to or aggravated his illnesses. A legal presumption of causation existed under the Act, placing the burden on the employer to rebut it, which the Bureau of Posts failed to do, as it only questioned the compensation amount, not the compensability itself.
Second, the WCC’s grounds for denial were legally untenable. The absence of an X-ray report is not an indispensable prerequisite for compensation; a physician’s report suffices, as it logically implies a prior examination was conducted. Furthermore, the claimant’s failure to take sick leave does not preclude entitlement to benefits. The Court emphasized that denying compensation to an employee who continues working despite illness would penalize laudable efforts and constitute inequitable discrimination. Finally, considering the case had been pending for over a decade, the Court opted to resolve it on the merits to serve the interest of justice, rather than remanding it for further administrative proceedings. The Bureau of Posts was ordered to pay disability benefits, reimburse medical expenses, and cover attorney’s fees.