GR 42507; (February, 1978) (Digest)
G.R. No. L-42507 February 28, 1978
CARLITA C. TRINIDAD, for herself and in behalf of her minor children, petitioners, vs. WORKMEN’S COMPENSATION COMMISSION and BATANGAS LAGUNA TAYABAS BUS CO., respondents.
FACTS
Leandro Trinidad, a stockman for Batangas Laguna Tayabas Bus Company (BLTB), worked as usual on May 14, 1974. After office hours, he went home, later complained of chest oppression and dizziness, and was brought to Calamba Emergency Hospital where he was pronounced dead on arrival. The death certificate listed the cause as cardio-respiratory failure secondary to cerebrovascular hemorrhage. His widow, Carlita Trinidad, filed a claim for death compensation on behalf of herself and their five minor dependent children. A hearing officer awarded compensation, but upon the employer’s motion, the case was elevated to the Workmen’s Compensation Commission.
The Workmen’s Compensation Commission set aside the award and dismissed the claim. It ruled that the illness causing death did not arise out of or in the course of employment. The Commission held that the claimants could not avail of the statutory presumption of compensability because they failed to establish a “preliminary link” between the cerebrovascular hemorrhage and the nature of Trinidad’s work as a stockman.
ISSUE
Whether the death of Leandro Trinidad, which occurred on the same day he worked, is compensable under the Workmen’s Compensation Act.
RULING
Yes, the death is compensable. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic is anchored on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. The Court emphasized that where an illness or death supervenes during the course of employment, as was undisputed here, the law presumes that the claim is compensable. The burden to rebut this presumption by substantial evidence shifts to the employer.
The Commission erred in requiring the claimants to first establish a “preliminary link” between the illness and the employment. This requirement had long been overturned by jurisprudence. The Court cited Naira v. Workmen’s Compensation Commission, which held that the mere absence of evidence linking the mishap to employment is insufficient to reject a claim; the employer must positively show it was not work-related. Here, BLTB failed to present credible evidence to overthrow the presumption. The fact that Trinidad worked on the day he died, performing duties as a stockman which involved physical strain, and that the fatal cerebrovascular accident occurred in the course of employment, was sufficient to invoke the presumption. The Court noted that for legal purposes, probability, not medical certainty, is the standard in determining work-connection. Consequently, the employer was ordered to pay death compensation, burial expenses, attorney’s fees, and administrative costs.