G.R. No. L-42893 September 30, 1976
LEOPOLDO AYUSO (substituted by APOLONIA BAUTISTA), petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and WHITE WAYS, INC., respondents.

FACTS

Leopoldo Ayuso was employed as a laborer by White Ways, Inc. from 1970 until his separation on August 31, 1972. His duties involved menial tasks such as cleaning toilets and medicine containers and making repairs. Prior to this employment, he worked from 1965 to 1970 for “Better Buildings,” a sister company of White Ways, Inc. During his tenure with Better Buildings, Ayuso was already suffering from a coronary disease, leading to hospital confinements in 1967 and 1968. While employed with White Ways, he was again hospitalized in November 1972, where physicians diagnosed him with pulmonary tuberculosis secondary to primary lung disease and an enlarged heart. The attending doctors certified that his lung ailment was aggravated by his work and that he was unfit for strenuous labor. Ayuso filed a compensation claim in May 1973 but died in August 1975, leading to his wife’s substitution as petitioner.
The respondent Workmen’s Compensation Commission denied the claim, ruling that Ayuso failed to prove he contracted his illness during his employment with White Ways, Inc. and that his separation was due to the company’s business closure, not his illness. The Commission also found no substantial evidence that his illness incapacitated him for labor prior to his separation.

ISSUE

Whether the death and illness of Leopoldo Ayuso are compensable under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the Commission’s decision and awarded compensation benefits. The legal logic rests on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. The Court found that Ayuso’s illness supervened during his employment with White Ways, Inc. Given his prior medical history known to the sister company, White Ways, Inc. assumed the risk of further aggravation when it hired him. This supervenience triggers the rebuttable presumption that the illness arose out of or was aggravated by the employment, shifting the burden of proof to the employer to disprove this causal link.
Private respondent White Ways, Inc. failed to rebut this presumption. The Physician’s Report indicated Ayuso’s disability was “total,” and medical opinions confirmed his work aggravated his condition. The fact that he continued working out of necessity does not negate his total disability for strenuous labor, which his job entailed. Furthermore, the reason for his separation—the expiration of the company’s business license—does not extinguish the employer’s liability for an illness incurred during employment. Consequently, the employer is liable for permanent total disability benefits in the amount of P6,000.00 plus attorney’s fees.