GR 43220; (October, 1980) (Digest)
G.R. No. L-43220 October 28, 1980
CANUTO CADIENTE, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION AND REPUBLIC OF THE PHILIPPINES (Rice and Corn Administration), respondents.
FACTS
Canuto Cadiente, employed by the National Grains Authority (NGA) and its predecessor agencies since 1954, worked as a janitor and later as a security guard. His duties involved cleaning bathrooms, premises, and garbage disposal. In April 1968, he began experiencing chest and back pains with afternoon fever. He was diagnosed with pulmonary tuberculosis by the company physician, Dr. Policarpio Cruz, and later by the Municipal Health Officer of Carmona, Cavite. The ailment progressed from minimal to moderately advanced. Cadiente stopped working on May 20, 1970, and was retired from service due to this illness. He filed a claim for disability compensation benefits, which the Acting Referee granted, awarding him P6,000.
The Workmen’s Compensation Commission (WCC) reversed the Referee’s decision, absolving the NGA from liability. The WCC ruled that it was not sufficiently established that Cadiente left service specifically due to his tuberculosis, despite the Referee’s factual finding that his retirement was illness-related. The Commission’s reversal prompted Cadiente to elevate the case to the Supreme Court.
ISSUE
Whether the Workmen’s Compensation Commission erred in absolving the employer from liability despite the presence of facts establishing a compensable claim under the Workmen’s Compensation Act.
RULING
The Supreme Court reversed the WCC decision and reinstated the award. The legal logic rests on the statutory presumptions of compensability under the Workmen’s Compensation Act. The Court emphasized that when an illness supervenes during employment, as Cadiente’s tuberculosis did in 1968 during his tenure with NGA, it is presumed to have arisen out of or been aggravated by such employment. This presumption is rebuttable.
Here, the employer, NGA, failed to rebut this presumption. It did not file an answer to the claim or present evidence to disprove the work-connection. The Court found the Acting Referee’s factual findings—that Cadiente’s duties were strenuous and that his retirement was due to his illness—to be supported by evidence. The WCC’s conclusion was erroneous for disregarding these established facts and the legal presumption. The failure of the employer to controvert the claim not only reinforced the presumption but also warranted the award. Consequently, the employer was ordered to pay Cadiente P6,000 in disability benefits, P600 in attorney’s fees, and P61 as an administrative fee.