G.R. No. L-43302 August 31, 1976
ELENA JACOB, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.

FACTS

Petitioner Elena Jacob was employed as a classroom teacher by the respondent Bureau of Public Schools starting July 1951. Her assignments were in remote, inaccessible barrios, requiring travel over long, rough roads and crossings of streams, often in the rain and sometimes missing meals. She also prepared lesson plans late into the night. In 1965, she began suffering asthmatic attacks and was later diagnosed with pulmonary tuberculosis. This illness forced her to take frequent sick leaves until her retirement in June 1974. On March 21, 1975, she filed a claim for disability benefits under the Workmen’s Compensation Act, submitting a Physician’s Report, her service record, an affidavit, and a clinical history from Dr. Angelita F. Ago detailing her hospitalization in 1973, which included x-ray results showing “PTB Moderately Advanced.” The respondent Bureau presented no evidence. The Acting Referee dismissed the claim for alleged insufficiency of evidence, citing a lack of an x-ray report prior to retirement. This dismissal was affirmed by the Workmen’s Compensation Commission, which ruled the illness discovered in 1975 was not traceable to her employment due to the terminated employer-employee relationship.

ISSUE

Whether the Workmen’s Compensation Commission committed grave abuse of discretion in dismissing the claim for disability benefits due to alleged insufficiency of evidence.

RULING

Yes. The Supreme Court reversed the Commission’s decision and awarded benefits to the petitioner. The legal logic is anchored on the presumption of compensability under the Workmen’s Compensation Act and the Commission’s duty to actively ascertain the facts. The Act presumes that a claim is compensable if the illness supervened during employment. The respondent employer failed to rebut this presumption by presenting no evidence. The Commission erred in insisting on a specific x-ray report when the petitioner had already submitted a Physician’s Report and a detailed clinical history from Dr. Ago, which explicitly referenced the x-ray findings of “PTB Moderately Advanced.” The Court held that if the Commission deemed the evidence insufficient, it was empowered and indeed duty-bound under Section 49 of the Act and its own rules to order the taking of additional testimony or require the submission of the x-ray report, rather than dismiss the claim outright. The failure to do so, especially given the unrebutted evidence of the arduous working conditions contributing to her illness, constituted a grave abuse of discretion. The illness having arisen during her employment, the claim was compensable.