G.R. No. L-43280 December 26, 1984
Florentino R. Matta, petitioner, vs. Workmen’s Compensation Commission and Development Bank of the Philippines, respondents.

FACTS

Petitioner Florentino R. Matta was employed by the Development Bank of the Philippines (DBP) from 1947 until his retirement in 1972, holding various positions including chief guard and assistant purchasing officer. On January 18, 1960, while serving as chief guard, a fire broke out at DBP’s building. In attempting to extinguish the fire, his eyes were sprayed with a fire extinguisher’s chemical contents, causing injury. He was hospitalized and subsequently experienced blurring of vision.
Over the years, Matta’s vision problems persisted, leading to a diagnosis of bilateral cataracts, coupled with diabetes mellitus and a heart ailment. He underwent cataract surgery in 1966 and was eventually forced to retire in 1972 due to disability. In 1975, he filed a claim for compensation benefits under the Workmen’s Compensation Act. Both the Acting Referee and the respondent Commission denied his claim, ruling that his cataract was a result of the aging process and not work-connected, and that he failed to present sufficient evidence.

ISSUE

Whether petitioner’s illness and resulting disability are compensable under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the Commission’s decision and granted the claim. The legal logic rests on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. Once an illness supervenes during employment, it is presumed to have arisen out of or been aggravated by such employment. The burden to rebut this presumption with substantial evidence lies with the employer.
Here, Matta’s eye injury directly occurred from an accident (the fire) arising out of and in the course of his employment as a chief guard. His subsequent cataract development and related ailments supervened during his employment. DBP failed to present substantial evidence to disconnect these illnesses from his employment or to overcome the legal presumption. Furthermore, DBP failed to effectively controvert the claim within the statutory period prescribed by Section 45 of the Act, which constitutes a renunciation of its right to challenge the claim’s compensability. Applying the principle that all doubts in labor legislation should be resolved in favor of the worker, the Court found the claim compensable. DBP was ordered to pay disability compensation, reimburse medical expenses, and pay attorney’s fees.