G.R. No. L-43108 June 30, 1976
PRAXEDES R. REYNALDO, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools) and the WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Praxedes R. Reynaldo was a public school teacher employed by the Bureau of Public Schools since 1948. Her duties included preparing lesson plans, checking test papers, teaching pupils, and attending seminars. After 25 years of service, she contracted aphakia, bilateral and chorio-retinal degeneration, right, which severely impaired her eyesight. She underwent an operation, was hospitalized, and eventually retired at age 55 due to the aggravation of her illness. She filed a claim for compensation benefits under the Workmen’s Compensation Act. The respondent Bureau, despite due notice, failed to file an employer’s report or controvert the claim. The Acting Referee of Regional Office No. IV awarded compensation benefits to Reynaldo.
The respondent Workmen’s Compensation Commission, on appeal, reversed the award and dismissed the claim. The Commission held that the illness, described as “chorio-retinal degeneration,” was degenerative and not compensable per se. It absolved the respondent Bureau from liability, prompting Reynaldo to elevate the case to the Supreme Court.

ISSUE

Whether the petitioner’s eye illness is compensable under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award. The legal logic is anchored on three key principles under the Workmen’s Compensation Act. First, the statutory presumption under Section 44 applies: an illness that supervenes during employment is presumed to have arisen out of or been aggravated by that employment. The burden to rebut this presumption shifts to the employer. Here, the petitioner entered service in good health, and her illness manifested during her employment. The respondent Bureau failed to present any substantial evidence to discharge its burden of proving the illness was not work-related or aggravated.
Second, the nature of the petitioner’s work as a teacher, which required prolonged and intensive use of her eyes for reading, checking papers, and preparing lessons, directly predisposed her to such an ailment. The Court found that her working conditions were traceable to her illness, a connection inferable from the established facts and even acknowledged as a possible aggravating factor in the medical report of Dr. Jesus Tamesis.
Third, and decisively, the respondent Bureau’s failure to controvert the claim within the statutory period constituted a waiver of all defenses, including the defense that the illness was not compensable. This failure alone renounced its right to dispute the claim’s merits. Therefore, the Commission erred in dismissing the claim based on a characterization of the illness as “degenerative,” as this defense was already barred. The award of permanent disability compensation and medical reimbursement by the Acting Referee was correct and is hereby affirmed.