GR 41985; (February, 1977) (Digest)
G.R. No. L-41985 February 28, 1977
ASUNCION VDA. DE GALLER, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and THE PHILIPPINE PACKING CORPORATION, respondents.
FACTS
Eustaquio Galler worked as a field worker for respondent Philippine Packing Corporation for 17 years, performing manual labor such as weeding, harvesting, and fertilizing pineapple plants, which exposed him to the elements. For months preceding his death on May 17, 1967, he complained of pains in his chest, back, and nape. He died in his sleep. The Acting Referee awarded death compensation benefits to his widow and five minor children, finding the death compensable.
The Workmen’s Compensation Commission reversed the Referee’s decision, absolving the employer from liability. The Commission dismissed the deceased’s pre-death pains as mere muscle fatigue unrelated to a compensable illness. It further held that since the death occurred during sleep, ten hours after work, and there was no evidence of extraordinary exertion or a pre-existing heart condition, a causal link to employment could not be presumed.
ISSUE
Whether the death of Eustaquio Galler is compensable under the Workmen’s Compensation Act.
RULING
Yes, the death is compensable. The Supreme Court reversed the Commission’s decision. The legal logic rests on the statutory presumption of compensability under the Workmen’s Compensation Act. When an illness supervenes during employment, it is presumed to have arisen out of or been aggravated by such employment. The burden to disprove this presumption by substantial evidence lies with the employer.
Here, the respondent corporation failed to discharge this burden. The Court found the Commission’s reasoning flawed. The deceased’s complaints of chest, back, and nape pains, which manifested only in the months before his death after 17 years of the same strenuous work, were likely symptoms of an illness incurred in the course of employment, not mere transient fatigue. The fact of death during sleep does not sever the connection to employment, as the law recognizes that satisfying essential human needs like sleeping is within the course of employment unless clearly shown otherwise. The cause of death listed on the death certificate (“Bangungot”) was not conclusive, especially absent an autopsy, and did not preclude other work-related causes like heart failure. Consequently, the presumption of compensability stands unrebutted. The Court awarded the full death benefit of P6,000.00, plus burial expenses, attorney’s fees, and administrative costs.