G.R. No. L-43018 October 28, 1977
LOURDES S. BELLO, assisted by her husband, FRED N. BELLO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC SCHOOLS), respondents.

FACTS

Petitioner Lourdes S. Bello was a public school teacher employed by the Bureau of Public Schools since 1965. In September 1973, she contracted Pulmonary Tuberculosis, Minimal with fibrosis, which her physician attributed to the nature of her employment involving classroom duties, civic action work, and exposure to the elements. Due to this illness, she stopped working and her services were terminated on October 1, 1973. The respondent employer did not controvert her claim for compensation.
The Acting Chief of the Workmen’s Compensation Unit initially awarded Bello P823.16, computed based on a 12% Non-Scheduled Disability rating. Petitioner moved for reconsideration, arguing the award failed to address her main claim for illness compensation under Sections 13, 14, or 16 of the Workmen’s Compensation Act. The Workmen’s Compensation Commission affirmed the limited award. Petitioner thus elevated the case, contending she was forced to resign due to her sickness, had been jobless since, and was entitled to full disability benefits.

ISSUE

Whether petitioner is entitled to total disability compensation benefits under Section 14 of the Workmen’s Compensation Act, rather than the limited award for partial disability.

RULING

Yes. The Supreme Court modified the decision and granted total disability compensation. The legal logic centers on the statutory definition of “disability” under the Workmen’s Compensation Act. Disability is not merely the physical injury or illness itself, but the loss or diminution of earning power resulting from an injury or disease arising out of and in the course of employment. Compensation is for the incapacity to work and the consequent impairment of earning capacity.
The Court found that Bello was in good health when she began employment in 1965. Her pulmonary tuberculosis, which supervened during her employment, is presumed to be work-related, a presumption not rebutted by the employer. The illness compelled her resignation at age 31. Since her resignation, she had been unable to work, and her condition rendered her physically incapable of performing her teaching duties. Furthermore, given the nature of her communicable disease, no employer would likely accept her services, as medical examinations are standard pre-employment requirements. This situation constitutes total disability, as she was disabled from rendering further service in her customary work or any work she was capable of performing.
Therefore, her case falls under Section 14 of the Act, which provides compensation for total disability, with a maximum award of Six Thousand Pesos. The Court also awarded medical expenses supported by receipts and ordered the provision of continuous medical services. The award was aligned with precedent, specifically Castro vs. Workmen’s Compensation Commission, where a teacher with a similar condition was granted the maximum compensation.