GR 43099; (May, 1977) (Digest)
G.R. No. L-43099. May 31, 1977.
TEOFILA GUEVARRA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondent.
FACTS
Petitioner Teofila Guevarra was employed as a public school teacher by the respondent Bureau of Public Schools from 1932 until the Japanese Occupation and again from 1948. Initially in good health, she suffered an attack of severe dizziness and unconsciousness in 1972, diagnosed as “Oartic Insufficiency.” By June 1974, she experienced frequent sore throat, hoarseness, and fever, leading to hospitalization where she was diagnosed with Pharyngitis, Pulmonary Tuberculosis, and Essential Hypertension. Due to this deteriorating health, which included an E.E.N.T. specialist’s advice for complete bed rest, she was constrained to apply for optional retirement, approved on September 16, 1974.
On January 8, 1975, Guevarra filed a claim for compensation benefits. The Workmen’s Compensation Unit awarded her benefits for total and permanent partial disability. However, the Workmen’s Compensation Commission reversed this award upon review, concluding her ailments had no causal relationship with her employment. The Commission also noted the alleged tardiness in filing her notice of claim.
ISSUE
Whether petitioner’s ailments (Hypertrophic Pharyngitis, Essential Hypertension, and Pulmonary Tuberculosis) are compensable under the Workmen’s Compensation Act.
RULING
Yes, the ailments are compensable. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic rests on the established rebuttable presumption under the Workmen’s Compensation Act that an illness which supervenes during employment either arose out of or was aggravated by that employment. The burden to overthrow this presumption lies with the employer. In this case, the respondent Republic failed to present substantial evidence to disconnect the illnesses from Guevarra’s work. A committee report indicated her conditions were probably caused by the nature of her teaching employment, involving hard work, tension, and overuse of her voice. Furthermore, her physical incapacity was substantiated by the approval of her optional retirement at age 62 under a memorandum requiring a finding of physical incapacity for efficient service. Regarding the tardy filing of the claim, the Court ruled the delay non-jurisdictional, as the employer had knowledge of her illness since August 1974 and did not suffer prejudice from the delay. Consequently, Guevarra was entitled to disability benefits, reimbursement for medical expenses, attorney’s fees, and an administrative fee.