GR 42203; (December, 1978) (Digest)
G.R. No. L-42203 December 29, 1978
AURORA F. DIZON, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and DEPARTMENT OF FOREIGN AFFAIRS, respondents.
FACTS
Aurora F. Dizon, a foreign service officer, filed a claim for compensation on May 24, 1974, alleging she developed a psychiatric illness (anxiety reaction with depressive features) in 1964 while assigned in Geneva due to alleged maltreatment, and that this illness was caused or aggravated by her employment. The claim was dismissed by the Labor Referee, a decision affirmed by the Workmen’s Compensation Commission. The Referee and Commission found the illness was not due to nor aggravated by her employment, relying heavily on the report of her own physician, Dr. Baltazar V. Reyes.
The record shows Dizon began work in 1959. After developing symptoms in 1964, she was recalled to the Philippines and treated by Dr. Reyes in February 1965. Despite this, she continued working regularly from 1966 onward. The leaves of absence she took between 1964 and 1966 were primarily for vacation, personal reasons, or minor ailments like colds and influenza; only one three-day leave in February 1965 was cited as due to “Mental Fatigue.” Her physician’s report explicitly stated her illness was not a result of her employment and that she could continue working.
ISSUE
Whether petitioner Aurora F. Dizon is entitled to compensation benefits under the Workmen’s Compensation Act for her psychiatric illness.
RULING
No. The Supreme Court affirmed the decision of the Workmen’s Compensation Commission, denying the claim. While the law presumes that an illness supervening during employment is work-related or aggravated by it, this presumption is disputable and was successfully rebutted in this case. The Court emphasized that the petitioner’s own evidence, specifically the physician’s report from Dr. Reyes, conclusively stated that her psychiatric condition was neither due to nor aggravated by the nature of her employment. This medical finding directly contradicted the legal presumption.
Furthermore, the Court found no evidence of compensable disability. The petitioner continued her employment without significant interruption, and her documented leaves of absence were largely unrelated to her claimed psychiatric ailment. The single leave for “Mental Fatigue” was insufficient to establish a disabling condition compensable under the Act. Since the claimant failed to substantiate that her illness was work-connected or that it resulted in disability, the claim was properly dismissed for lack of merit. The presumption was overcome by contrary medical evidence and the factual circumstances of continued employment.