G.R. No. L-40658 June 30, 1976
Crisostomo Aranzanso, petitioner, vs. Honorable Associate Commissioner Eugenio I. Sagnit, in his capacity as Associate Commissioner of Workmen’s Compensation Commission and Gami Machineries, Inc., respondents.

FACTS

Petitioner Crisostomo Aranzanso worked as a carpenter for respondent Gami Machineries, Inc., starting in 1968, with a demanding schedule of eight hours daily, six days a week, and often including Sundays. On September 5, 1971, while on a vacation leave, he suffered a stroke and was hospitalized. Medical evaluations from the Workmen’s Compensation Section later determined he was totally disabled from September 16, 1971, to February 20, 1973, and had a 60% permanent partial disability. He filed a claim for disability benefits under the Workmen’s Compensation Act.
The Acting Referee of Regional Office No. 4 granted his claim, awarding compensation and medical reimbursement. The respondent employer moved for review, contending the illness was not compensable as it occurred while Aranzanso was on vacation and was not work-connected. The Workmen’s Compensation Commission reversed the award and dismissed the claim, applying the doctrine from A.L. Ammen Transportation Co. vs. WCC that an injury sustained on leave is not compensable, as the worker was not at the place of work or performing work duties.

ISSUE

Whether the petitioner’s illness, which manifested during a period of authorized vacation leave, is compensable under the Workmen’s Compensation Act.

RULING

Yes, the illness is compensable. The Supreme Court reversed the Commission’s decision and reinstated the Acting Referee’s award. The legal logic proceeds from a rejection of a rigid application of the A.L. Ammen doctrine to the specific context of a vacation leave. The Court held that an employee on authorized vacation does not cease to be an employee; the vacation period is considered part of the employment period as a matter of public policy intended for the worker’s health and well-being. Consequently, an illness arising during this interval is deemed to have arisen out of the employment.
Crucially, the Court invoked the statutory presumption of compensability under the Workmen’s Compensation Act. Once an illness occurs or is aggravated during employment, it is presumed compensable, and the burden shifts to the employer to disprove this connection by substantial evidence. The respondent employer failed to meet this burden. It did not prove that Aranzanso’s cerebro-vascular attack was caused by factors unrelated to his strenuous work as a carpenter. The Court further clarified, citing Abana vs. Quisumbing, that the employment need not be the sole cause; it is sufficient if it contributed even in a small degree to the development or acceleration of the disease. The claim’s probability, not absolute certainty, is the standard for compensability. Therefore, the Commission erred in dismissing the claim based solely on the timing of the illness’s onset during vacation.