G.R. No. L-43089. January 31, 1977.
CIRILA LEGASON, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.

FACTS

Petitioner Cirila Legason was employed as a classroom teacher by the respondent Republic of the Philippines (Bureau of Public Schools) from June 11, 1923. In the course of her employment, she contracted hypertension, hypertensive heart disease, and tuberculosis of the lungs. Due to these ailments, she was compelled to retire on August 31, 1966, under Republic Act No. 660 , at the age of 63 after over 40 years of service. In September 1972, she filed a claim for disability compensation. The Acting Labor Referee awarded her compensation benefits.
The respondent Republic made a tentative controversion but failed to present any evidence during the hearing. On review, the Workmen’s Compensation Commission reversed the referee’s decision and dismissed the claim. The Commission ruled that Legason was not disabled prior to retirement, as her retirement was due to age and length of service, and that she was merely suffering from hypertension. The Commission disregarded the evidence on record, including a Report of Sickness and a Local Claims Committee Report detailing her work-related ailments and incapacity.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing petitioner’s claim for disability compensation.

RULING

Yes. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic is anchored on the statutory presumptions under the Workmen’s Compensation Act and the employer’s failure to rebut them. First, once an illness supervenes during employment, it is presumed to arise out of or be aggravated by such employment. The burden to overthrow this presumption shifts to the employer. Here, the respondent Republic failed to present any contrary evidence despite its tentative controversion, which amounts to a failure to controvert. This failure is fatal and constructively admits the claim’s compensability.
Second, the Commission’s conclusion was unsupported by evidence. The Local Claims Committee Report and physician’s findings established that Legason’s ailments—hypertensive heart disease and tuberculosis—were directly caused and aggravated by her teaching duties, which involved emotional strain, supervision of children, and exposure to the elements during her commute. Furthermore, her optional retirement under Republic Act No. 660 at age 63, approved under Memorandum Circular No. 133, required a finding that she was “physically incapacitated to render further efficient service.” This official approval conclusively demonstrates her disability for work. Therefore, her retirement was due to physical incapacity, not merely age. The claim is compensable under Section 2 of the Act, as her illnesses were aggravated by the nature of her employment.