G.R. No. L-19772; October 21, 1964
CELEDONIA O. VDA. DE ACOSTA, ET AL., petitioners, vs. THE WORKMEN’S COMPENSATION COMMISSION and THE MANILA RAILROAD COMPANY, respondents.

FACTS

The petitioners, heirs of the deceased Bernardo Acosta, filed a claim for compensation under the Workmen’s Compensation Act. Acosta had been employed as a switchman by the Manila Railroad Company for over twenty years. Medical examinations from 1947 to 1953 revealed normal lung conditions. However, an examination in March 1956 diagnosed him with pulmonary tuberculosis. He stopped working in January 1960 due to his illness, retired in May 1960, and died from the disease in June 1960 at age 59. The hearing officer awarded compensation, finding the illness was contracted or aggravated by the nature of his employment.
The respondent company filed a motion for reconsideration. The Chairman of the Workmen’s Compensation Commission reversed the hearing officer’s decision, a ruling affirmed by the Commission en banc. The Commission held that the petitioners failed to satisfactorily prove that the necessary factors to cause or aggravate tuberculosis existed in Acosta’s employment, noting a lack of specific details on the strenuousness of his duties like loading cargo.

ISSUE

Whether the illness (pulmonary tuberculosis) that caused Bernardo Acosta’s death arose out of or was aggravated by the nature of his employment, making it compensable under the Workmen’s Compensation Act.

RULING

The Supreme Court reversed the Commission’s decision and reinstated the award. The Court applied the established legal presumption under the Workmen’s Compensation Act: once it is shown that an illness was contracted or aggravated in the course of employment, it is presumed that the illness arose out of or was aggravated by such employment. The burden then shifts to the employer to rebut this presumption.
In this case, the medical history—showing normal lungs during employment until the disease manifested and progressed to cause death—established that the illness was contracted during employment. The Court found the Commission’s reasoning erroneous. Evidence, including testimony from a company witness, corroborated that Acosta’s duties as a switchman at a small station included loading and unloading cargoes, as there were no dedicated porters. The Commission’s demand for precise quantification of this strenuous activity was an overly strict standard not required by law.
The respondent company failed to discharge its burden of proof to overcome the statutory presumption. It did not present evidence that the cause of the illness or its aggravation was due to factors unrelated to his work, such as personal habits or external causes. Therefore, the illness and resulting death were compensable. The Court ordered the Manila Railroad Company to pay the compensation benefits as originally awarded by the hearing officer.