G.R. No. L-43258 September 30, 1977
MARIA V. VILLEGAS, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.

FACTS

Petitioner Maria V. Villegas, widow of Vicente Villegas, filed a claim for death compensation benefits and reimbursement of medical expenses after her husband’s death. Vicente, a Division Superintendent of Public Schools for Eastern Samar with over thirty years of service, died from uremia and metastatic carcinoma of the rectum in November 1970. His duties involved extensive travel to remote areas. In 1967, he experienced bodily weakness but continued working. In February 1970, while supervising a construction project, he suffered severe vomiting and loose bowel movements but persisted in his work. He was later diagnosed with adenocarcinoma of the rectum, diabetes mellitus, and hypertension. He retired in May 1970 and died after surgery complications.
The Hearing Referee awarded death compensation, burial expenses, and medical reimbursement. The employer, the Republic (Bureau of Public Schools), through the Assistant Provincial Fiscal, initially endorsed the decision, admitting the claim’s compensability. The employer later contested only the amount of medical expenses as excessive, filing a request for reevaluation and a petition for review with the Workmen’s Compensation Commission on this limited ground.

ISSUE

Did the Workmen’s Compensation Commission act with grave abuse of discretion by reversing the Hearing Referee’s award on the ground of non-compensability, when the employer had previously admitted compensability and only questioned the amount of the award?

RULING

Yes. The Supreme Court ruled for the petitioner. The Commission exceeded its authority by reopening the issue of compensability. The employer’s initial endorsement of the Hearing Referee’s decision constituted an admission that the claim was compensable. Furthermore, the employer’s subsequent petition for review solely questioned the reasonableness of the medical expenses, not the underlying compensability of the illness. Consequently, the Hearing Referee’s finding of compensability had become final and conclusive between the parties. The Commission’s decision to deny the claim on the merits of compensability was a grave abuse of discretion, as it decided an issue not properly appealed and already settled.
The Court further held that, even assuming the issue was open, the claim was compensable under the Workmen’s Compensation Act. The statutory presumption of compensability under Section 44 of the Act applied, as the illness supervened during employment. The employer failed to present substantial evidence to rebut the presumption that the work contributed to the illness’s aggravation. The nature of Vicente’s duties, involving stress and extensive travel, could have accelerated his condition. The Court reversed the Commission’s decision and reinstated the award made by the Hearing Referee.