G.R. No. L-44822. February 29, 1988.
ESPIRITA B. BUENDIA, petitioner, vs. THE WORKMEN’S COMPENSATION COMMISSION and the REPUBLIC OF THE PHILIPPINES (DEPARTMENT OF EDUCATION AND CULTURE), respondents.

FACTS

Petitioner Espirita B. Buendia was a classroom teacher employed by the Bureau of Public Schools since 1933. Her duties involved teaching multiple subjects, extensive preparation work at night, student consultations, home visitations requiring travel, and attendance at weekend seminars. During her employment, she developed multiple ailments—Anemia, Hypotension, Articular Rheumatism, and Diabetes—diagnosed in 1970. Her attending physician opined these conditions resulted from and were aggravated by her employment, leading to permanent total disability and advising retirement. Buendia retired on August 26, 1973, and subsequently filed a claim for disability benefits under the Workmen’s Compensation Act.
The Acting Referee awarded disability compensation, finding the illnesses work-related. However, the Workmen’s Compensation Commission reversed this decision on appeal. The Commission held that Buendia failed to prove she suffered disability during her tenure, noting she worked continuously until retirement without recorded absences due to illness. It ruled that mere sickness, without demonstrated work incapacity during employment, is not compensable.

ISSUE

Whether the petitioner is entitled to disability compensation benefits under the Workmen’s Compensation Act despite her retirement, and whether her claim is barred for alleged failure to prove disability occurring during her employment.

RULING

The Supreme Court reversed the Commission’s decision and reinstated the award. On procedural grounds, the Court exercised its equity jurisdiction to overlook any delay in filing, considering the administrative confusion during the transition from the Workmen’s Compensation Commission to the new Employees Compensation scheme and petitioner’s status as a pauper litigant.
On the merits, the Court applied the legal presumption under Section 44 of the Workmen’s Compensation Act that an illness which supervenes during employment is presumed to arise out of or be aggravated by such employment. This presumption shifts the burden of proof to the employer to disprove compensability. The respondent failed to present evidence to rebut this presumption, as it did not attend the hearings or submit contrary medical proof. The Commission erred in requiring petitioner to show disability manifested through absences during her tenure. Jurisprudence establishes that an employee compelled to retire due to a work-related disability is entitled to compensation for permanent disability. The fact of retirement itself, based on medical advice due to incapacitating illnesses, constitutes the compensable disability. The award was reinstated with an increase in attorney’s fees.