G.R. No. L-42598. December 29, 1978.
PEDRO CASTRO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES, respondents.

FACTS

Pedro Castro, employed as a laborer/acting bailiff by the Court of First Instance of Cebu since 1962, ceased work on October 28, 1974, due to pulmonary tuberculosis and hypertensive heart disease. He filed a claim for disability compensation on March 17, 1975. The Republic of the Philippines, as employer, contested the claim, arguing it was filed out of time and that no causal link existed between his illnesses and his employment.
The Acting Referee of Regional Office No. VII awarded compensation, finding the illnesses compensable and computing benefits under Sections 14 and 17 of the Workmen’s Compensation Act. The award included medical expenses and maximum disability compensation, totaling P6,584.62. The Workmen’s Compensation Commission reversed this decision on appeal, dismissing the claim on the ground that Castro was not disabled for work due to his illness, prompting Castro’s petition for review to the Supreme Court.

ISSUE

Whether or not the illnesses (pulmonary tuberculosis and hypertensive heart disease) suffered by Pedro Castro are compensable under the Workmen’s Compensation Act.

RULING

Yes, the illnesses are compensable. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic proceeds from the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. Since the Commission itself acknowledged that Castro contracted his illness in the course of employment, the law presumes the illness arose out of or was aggravated by said employment. This presumption, which is jurisprudentially entrenched, makes the claim compensable unless the employer presents substantial evidence to rebut it.
The respondent employer failed to overcome this presumption. Furthermore, Castro presented affirmative evidence, including medical findings, to establish the causal connection. The medical report from Compensation Rating Medical Officer Dr. Francisco Dayak confirmed a 62% permanent partial disability, alongside a period of temporary total disability. His compulsory retirement at age 64 due to this physical incapacity concretely demonstrated his disablement for labor. The Court found the Acting Referee’s computation of benefits—combining temporary total disability compensation for 52 weeks and permanent partial disability compensation for 128.96 weeks, capped at the legal maximum—to be in accordance with law. Consequently, the employer was ordered to pay the awarded compensation, attorney’s fees, and administrative costs.