G.R. No. L-47037 December 6, 1985
Eufracina Garcia, petitioner, vs. Compensation Appeals and Review Staff and Republic of the Philippines (Bureau of Public Schools), respondents.

FACTS

Petitioner Eufracina Garcia was a public school teacher from 1937 until her retirement in 1975. During her employment, she contracted pulmonary tuberculosis minimal and arteriosclerotic heart disease. Her condition worsened, leading her doctor to advise against strenuous exertion in March 1974. Consequently, she resigned on February 16, 1975, before reaching the compulsory retirement age of 65. Following her retirement, she filed a claim for disability compensation benefits, asserting that her ailments were work-connected and aggravated by her employment.
The Acting Referee initially granted her partial disability compensation. However, the Workmen’s Compensation Commission reversed this decision, holding that her illnesses were not work-connected. The Secretary of Labor affirmed the Commission’s dismissal. Garcia elevated the case to the Supreme Court via petition for review, contending she was entitled to the maximum disability benefit.

ISSUE

Whether petitioner Eufracina Garcia is entitled to total permanent disability compensation benefits under the Workmen’s Compensation Act for her ailments of arteriosclerotic heart disease and pulmonary tuberculosis.

RULING

Yes, the Supreme Court granted the petition and awarded full disability compensation. The legal logic rests on the established presumptions and principles under the Workmen’s Compensation Act. When an employee, who was in good health upon commencing employment, contracts an illness during service, it is presumed under Section 44 of the Act that the illness arose out of or was aggravated by the employment. The burden to rebut this presumption lies with the employer, which the respondent Bureau of Public Schools failed to discharge.
The Court emphasized that compensation is warranted if the employment contributed to the development or aggravation of the disease, even in a small degree. Citing jurisprudence, the Court ruled that heart diseases and pulmonary tuberculosis are compensable, especially for teachers whose strenuous work can aggravate such conditions. Since Garcia was forced to retire early due to her disabling illnesses, which supervened during her employment, she suffered permanent total disability. Denying her full benefits would contravene the constitutional mandate of social justice. Thus, the Commission’s decision was set aside, and the Bureau was ordered to pay Garcia P6,000.00 as disability compensation, plus attorney’s fees and administrative costs.