G.R. No. L-42450 September 30, 1976
JOSE B. CAPARAS, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and SEVEN UP BOTTLING COMPANY OF THE PHILIPPINES, respondents.

FACTS

Petitioner Jose B. Caparas was employed as a salesman-driver by private respondent Seven Up Bottling Company starting in 1957. In August 1966, he suffered from dizziness, severe headaches, and heart palpitations, which were diagnosed by his physician as “Hyperthyroid Heart Disease and Rheumatoid Arthritis.” He verbally notified his supervisor of his illness. Subsequently, on August 29, 1966, the respondent company sold its Calasiao Plant to San Miguel Corporation, leading to the plant’s closure. Although an unfair labor practice case filed by the employees’ association was later settled, the respondent could not rehire the petitioner due to his ongoing sickness.
On March 31, 1975, the petitioner filed a claim for compensation benefits with the Workmen’s Compensation Section, Regional Office No. 4. Without conducting a hearing, the Acting Referee dismissed the claim outright on the ground that his illnesses were non-compensable. This dismissal was affirmed by the respondent Workmen’s Compensation Commission, which considered the illnesses as non-occupational. The petitioner challenged this decision, alleging grave abuse of discretion and a denial of due process, as no evidence was formally received to support or rebut his claim.

ISSUE

Whether the respondent Commission acted with grave abuse of discretion in dismissing the petitioner’s claim for compensation benefits without receiving evidence and by failing to apply the statutory presumption of compensability under the Workmen’s Compensation Act.

RULING

The Supreme Court reversed the decision of the respondent Commission. The legal logic centers on the mandatory presumption established under the Workmen’s Compensation Act. Once an illness supervenes in the course of employment, the law raises a rebuttable presumption that the illness arose out of, or was aggravated by, the employment. This presumption shifts the burden of proof to the employer to disprove compensability.
In this case, the petitioner’s claim form and the attached Physician’s Report of Sickness explicitly stated that his ailments, while metabolic in origin, were aggravated by his employment. The symptoms manifested after long years of service. The Acting Referee and the Commission dismissed the claim based solely on an initial classification of the illnesses as “non-compensable” without requiring the employer to submit any counter-affidavit or evidence to rebut the presumption, as mandated by Department Order No. 3 implementing procedures for expediting claims. Since the private respondent failed to present any evidence to overcome the legal presumption, the presumption stands. Consequently, the illnesses are deemed compensable. The Court awarded the petitioner P6,000.00 as compensation for permanent total disability, P356.00 for medical expenses reimbursement, and attorney’s fees.