G.R. No. L-45203 August 20, 1979
SEBASTIAN DIMDIMAN, petitioner, vs. WORKMEN’S COMPENSENCE COMMISSION and PHILIPPINE NATIONAL RAILWAYS, respondents.

FACTS

Petitioner Sebastian Dimdiman, employed by the Philippine National Railways (PNR) from 1945 until his retirement in 1972, filed a claim for compensation benefits in 1973. He alleged suffering from illnesses including rheumatic heart disease, congestive heart failure, and osteoarthritis, which began manifesting symptoms in 1967. His condition worsened from 1970 onward, causing pain, swelling, and deafness, leading him to consult the company physician. He retired at age 58 under a disability plan, prior to the compulsory retirement age. The Hearing Officer of Regional Office No. I granted his claim, awarding disability compensation, medical reimbursement, and attorney’s fees.
The PNR appealed to the Workmen’s Compensation Commission (WCC), which reversed the Hearing Officer’s decision. The WCC dismissed the claim, ruling that the record lacked evidence showing Dimdiman suffered a disabling disease during his employment or was disabled at retirement. The WCC found no merit in the claim, prompting Dimdiman to elevate the case to the Supreme Court via petition for review.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing Sebastian Dimdiman’s claim for disability compensation benefits.

RULING

Yes, the Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award granted by the Hearing Officer. The legal logic is anchored on the presumption of compensability under the Workmen’s Compensation Act, a social legislation designed for the protection of labor. It is undisputed that Dimdiman’s illnesses supervened during his employment with PNR. This fact establishes the preliminary link giving rise to the disputable presumption that the claim is compensable. The burden of proof then shifts to the employer, PNR, to demonstrate by substantial evidence that the illness did not arise out of or was not aggravated by the employment.
The Court found that PNR failed to overcome this legal presumption. The evidence on record, including medical testimony, established that Dimdiman’s heart disease could be aggravated by his work and his arthritis could be caused by the nature of his duties. His early retirement under a disability plan approved by the GSIS further corroborated the work-related nature of his permanent total disability. Following the doctrine that all doubts should be resolved in favor of the laborer, the claim is compensable. The Court affirmed the award of P6,000.00 as maximum disability compensation and P520.67 for medical expenses, but increased the attorney’s fees to P600.00. The employer was also ordered to pay administrative costs.