GR 42543; (September, 1976) (Digest)
G.R. No. L-42543 September 30, 1976
AURORA C. VDA DE LEORNA, for herself and for her minor children: SABINA, SEVERINO SERGIO and SYLVIA, all surnamed LEORNA, petitioners, vs. WORKMEN’S COMPENSATION COMMISSION and LUZON STEVEDORING CORPORATION, respondents.
FACTS
Petitioner Aurora Vda. de Leorna filed a claim for compensation benefits following the death of her husband, Conrado Leorna, a stevedore laborer for respondent Luzon Stevedoring Corporation (LUSTEVECO). Conrado died on May 29, 1967, at age 62, from rheumatism with heart complication. The claim was initially granted by the Acting Referee of Regional Office No. 4, Department of Labor, on August 20, 1975. Respondent LUSTEVECO filed a motion for reconsideration. Subsequently, the Workmen’s Compensation Commission (WCC) reversed the regional office’s decision on November 24, 1975. The Commission ruled that the record was devoid of substantial proof establishing a causal link between the decedent’s employment and his death, holding that the presumption of compensability did not apply absent this preliminary connection.
ISSUE
Whether the death of Conrado Leorna is compensable under the Workmen’s Compensation Act.
RULING
Yes. The Supreme Court reversed the decision of the Workmen’s Compensation Commission. The legal logic is anchored on two primary grounds. First, respondent LUSTEVECO failed to controvert the claim within the statutory period, which constitutes a waiver of all non-jurisdictional defenses under Section 45 of Act No. 3428 , as amended. This procedural lapse alone is sufficient to sustain the award.
Second, on the merits, the presumption of compensability under Section 44(1) of the Workmen’s Compensation Act applies. This presumption mandates that in the absence of substantial evidence to the contrary, a claim is presumed to fall within the Act’s purview, placing the burden on the employer to disprove work-connection. Here, LUSTEVECO failed to present substantial evidence to rebut this presumption. Furthermore, the nature of Conrado Leorna’s work as a stevedore—involving strenuous physical labor, exposure to extreme weather conditions, dust, and irregular hours—provided the atmosphere for the development or aggravation of rheumatism, a disease recognized by medical authority as common among longshoremen. The Court emphasized that the Workmen’s Compensation Act is social legislation designed to effectuate the constitutional guarantee of social justice, a mandate that tribunals must observe, especially in favor of indigent claimants like the petitioner and her minor children. Respondent LUSTEVECO was ordered to pay compensation benefits, burial expenses, attorney’s fees, administrative fees, and costs.