G.R. No. L-41893 August 27, 1976
VICENTE C. GALANG, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and SAN MIGUEL CORPORATION, respondents.

FACTS

Petitioner Vicente C. Galang was employed as a laborer by San Miguel Corporation for twenty-four years, from 1946 to March 8, 1970. His work involved loading beer boxes onto trucks and ships at the pier. In early February 1970, he became ill and was diagnosed by his physician with “Hypertrophic Rheumatoid Arthritis, Essential Hypertension, Articular Arthritis and Ulcer (Chronic).” Due to these ailments, he applied for and was granted retirement under the company’s Health, Welfare and Retirement Plan, effective March 8, 1970. On June 14, 1974, he filed a claim for disability compensation.
The Hearing Officer awarded Galang compensation benefits, finding his illnesses work-related. However, the Workmen’s Compensation Commission (WCC) reversed this decision on appeal. The WCC dismissed the claim, reasoning that the illnesses were not per se disabling, that the physician’s report was insufficient proof of disability at the time of retirement, and that Galang’s retirement was motivated by a personal desire to “stay healthy and live longer,” as indicated in his retirement application, and not by compensable disability.

ISSUE

Whether the respondent Commission committed grave abuse of discretion in reversing the Hearing Officer’s award and dismissing Galang’s claim for disability compensation benefits.

RULING

Yes. The Supreme Court reversed the WCC’s decision and reinstated the Hearing Officer’s award. The legal logic is anchored on the established presumption of compensability under the Workmen’s Compensation Act. The Court held that once an illness supervenes during the course of employment, as Galang’s illnesses did in February 1970 while he was still working, the law presumes that such illness arose out of or was at least aggravated by the employment. The burden then shifts to the employer to rebut this presumption by substantial evidence.
In this case, Galang satisfactorily established through his physician’s report that his ailments—arthritis, hypertension, and ulcer—were aggravated by the strenuous nature of his work as a laborer involving heavy lifting over 24 years. San Miguel Corporation failed to present any countervailing evidence to overthrow the legal presumption. The Court found the WCC’s reliance on Galang’s retirement letter misplaced. A careful reading revealed his “desire to stay healthy” was directly prompted by his “feeling that his strength is gradually sagging due to his work,” which constituted a compelling health reason for retirement. His affidavit further stated he was forced to retire because he could no longer perform his duties. Therefore, his retirement was due to a compensable disability, entitling him to benefits under the Act. The WCC’s dismissal of the claim, contrary to this evidence and legal presumption, constituted a reversible error.