G.R. No. L-43317 December 29, 1978
JULIA P. PANTOJA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools) and WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Julia P. Pantoja was employed as a public school teacher from March 1, 1935, until her retirement on December 31, 1972. In January 1966, after over thirty years of service, she was diagnosed with chronic arthritis, coronary insufficiency, and hypertension. Her attending physician opined that her work, involving physical and emotional stresses, aggravated these conditions. Due to the worsening of her ailments, she was advised to retire, which she did at age 60, before the compulsory retirement age. On August 6, 1974, she filed a claim for disability benefits under the Workmen’s Compensation Act.
The Acting Referee awarded compensation, finding her illnesses compensable as they supervened during her employment. The respondent employer, the Bureau of Public Schools, failed to appear at hearings or present evidence to rebut the claim. Subsequently, the Solicitor General filed a “Petition to Elevate Records For Relief From Judgment.” The respondent Workmen’s Compensation Commission reversed the award, ruling there was no competent medical evidence showing Pantoja suffered a disabling illness at the time of her separation from service.

ISSUE

Whether the respondent Commission committed grave abuse of discretion in reversing the award of disability compensation to the petitioner.

RULING

Yes, the Supreme Court set aside the Commission’s decision. The legal logic rests on two established doctrines in workmen’s compensation. First, the presumption of compensability applies. It is undisputed that Pantoja was in good health when she began employment and that her illnesses manifested after over three decades of work. This gives rise to the rebuttable presumption that the illnesses arose out of or were aggravated by her employment, making them compensable. The burden to disprove this presumption shifted to the employer. Since the respondent employer failed to appear or present any contrary evidence, the presumption became conclusive. The Commission erred in absolving the employer despite this uncontroverted presumption.
Second, her early retirement itself is indicative of disability. Retirement at age 60, before the compulsory age, is allowed only upon a showing of physical incapacity to render efficient service. This circumstance substantiates her claim of work-related disability at the time of separation. The Commission’s requirement for additional medical evidence at the time of retirement disregarded this principle. Furthermore, the Solicitor General’s petition for relief was procedurally infirm, as the grounds cited did not constitute fraud, accident, mistake, or excusable negligence. The award had thus become final, and the Commission exceeded its jurisdiction in reviewing the merits. Consequently, the original award was reinstated.