GR 42565; (November, 1978) (Digest)
G.R. No. L-42565. November 21, 1978.
G. B. FRANCISCO, INC., petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and ALEJANDRO URDAS, respondents.
FACTS
Alejandro Urdas filed a claim for disability compensation, alleging he was employed as a painter by G. B. Francisco, Inc. from February 1966 to January 1967. He claimed that during his employment, he was diagnosed with Hansen’s Disease (leprosy) by Dr. Remigio Reyes of the Central Luzon Sanitarium, forcing him to stop work. His physician certified the illness was directly caused by his employment. As proof of employment, Urdas submitted a pay envelope from the company. The employer, G. B. Francisco, Inc., through counsel, denied Urdas was ever its employee but presented no evidence to substantiate this denial. The Acting Referee dismissed the claim, finding no substantial proof of employment and no reasonable connection between the illness and the work.
ISSUE
The primary issues were: (1) whether an employer-employee relationship existed between petitioner and Urdas; and (2) whether Urdas’s illness supervened in the course of employment and is thus compensable.
RULING
The Supreme Court affirmed the Workmen’s Compensation Commission’s award, holding the claim compensable. On the first issue, the Court found sufficient evidence of employment. Urdas presented a pay envelope from G. B. Francisco, Inc., which the employer failed to rebut with any credible proof. The Court emphasized that a mere denial, without supporting documentary evidence, is insufficient to overcome the claimant’s prima facie evidence. To rule otherwise would allow employers to easily evade liability through bare allegations.
On the second issue, the Court applied the presumption of compensability under the Workmen’s Compensation Act. Since the illness, Hansen’s Disease, supervened during employment, it is presumed to have arisen out of or been aggravated by the employment. This presumption was bolstered by the attending physician’s certification directly linking the illness to Urdas’s work. The employer’s failure to timely and validly controvert the claim rendered this presumption conclusive. Furthermore, the Court reiterated that any doubt regarding compensability must be resolved in favor of the laborer to serve the ends of social justice. The award of P6,000 as disability compensation and an attorney’s fee was thus sustained.