G.R. No. L-42776, L-42280, L-43230, L-43843, L-43484, L-43422, L-43056, L-42387, L-43334, L-43551, L-43545, L-43722. August 31, 1978.
MACAPASIR ALONTO, CONCEPCION VDA. DE GASCON, ROSENDO SATPARAM, NELIO DE MESA, CATALINO GABRIELES, CESAR ONG GAKO, BERNARDINO R. SAUVA, MAGNO CADORES, JOAQUINA OCLARIT, VIVENCIO PANONCILLO, SALVADORA C. REY, and FRANCISCA B. BENITEZ, petitioners, vs. THE WORKMEN’S COMPENSATION COMMISSION and THE REPUBLIC OF THE PHILIPPINES, et al., respondents.

FACTS

These twelve consolidated cases involve claims for death or disability benefits under the Workmen’s Compensation Act. In each instance, the petitioners, or their deceased relatives, were government or private employees who contracted illnesses, primarily pulmonary tuberculosis, during their employment. The Workmen’s Compensation Commission dismissed or reversed awards for compensation. The dismissals were typically based on the Commission’s finding of an absence of sufficient evidence to prove that the illness was work-related or that it caused the disability or death, despite the presence of Employer’s Reports admitting the sickness was contracted in the work premises or failures to timely controvert the claims.
For example, in Alonto’s case, the Employer’s Report admitted the sickness was contracted at work and stated the claim would not be controverted, yet the Commission dismissed it for lacking an X-ray report. In Gascon’s case, the Commission reversed an award for the widow, finding no “vital health of causative connection” despite the deceased’s retirement due to tuberculosis and subsequent death from the same disease within a year. Similar patterns of dismissal occurred in the other cases, often disregarding legal presumptions of compensability.

ISSUE

The central issue is whether the Workmen’s Compensation Commission committed reversible error in dismissing the claims, thereby disregarding established legal presumptions and principles under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the Commission’s decisions and reinstated the awards. The legal logic is anchored on the fundamental principle that the Workmen’s Compensation Act is a social legislation designed to provide relief to laborers. Under Section 44 of the Act, once an illness supervenes during employment, it is presumed to be work-related and compensable. The burden shifts to the employer to rebut this presumption by substantial evidence. In these cases, the employers failed to discharge this burden. The Commission erred by requiring the claimants to positively prove causation, which is contrary to the law’s presumption.
Furthermore, the employer’s failure to timely controvert the claim, as evidenced by the Employer’s Reports or inaction, results in a waiver of all non-jurisdictional defenses and renders the claim uncontroverted. The Commission cannot then introduce its own standards of proof, such as demanding specific medical reports like X-rays, to defeat the claim. The Court emphasized that physician’s reports and the circumstances of employment, such as long years of service and the nature of the work, are sufficient to establish compensability. The decisions of the Commission were deemed not supported by substantial evidence and constituted a grave abuse of discretion. The Court ordered the respective employers to pay the corresponding disability or death benefits, plus administrative fees.