G.R. No. L-43320 June 30, 1978
CECILIA V. ULIBAS, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools) and THE WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Cecilia V. Ulibas was a classroom teacher from 1930 until her retirement in 1968. Her duties involved extensive teaching, preparation of lesson plans and teaching aids, student consultations, and home visitations, often requiring her to work late into the night. During her employment, she began suffering from chronic poly articular rheumatism, chronic laryngitis, anemia-hypotension, and chronic weeping eczema. Her attending physician, Dr. Alfredo A. Cadena, diagnosed these conditions and advised her to retire as her work would aggravate her ailments despite treatment. She retired at age 60 due to her disabilities.
Ulibas filed a claim for disability compensation. The acting referee awarded her benefits, finding her ailments work-connected. The Republic, through the Solicitor General, filed a “Petition to elevate the records for relief from judgment” with the Workmen’s Compensation Commission (WCC) beyond the 15-day reglementary period for appeal, citing heavy workload. The WCC reversed the referee’s award and dismissed the claim. Ulibas petitioned the Supreme Court, arguing the referee’s award had become final and executory due to the late appeal and that her ailments were compensable.

ISSUE

The primary issue is whether the WCC acted with grave abuse of discretion in entertaining the late appeal and reversing the referee’s award. The secondary issue is whether Ulibas’s ailments are compensable under the Workmen’s Compensation Act.

RULING

The Supreme Court granted the petition, reinstating the referee’s award. On procedural grounds, the Court ruled the WCC committed grave abuse of discretion. The government’s petition for relief, filed beyond the mandatory 15-day appeal period, was invalid. The excuse of heavy workload in the Solicitor General’s office was unacceptable, as the State must adhere to the same procedural rules it enforces. The referee’s decision had thus become final and executory.
On the merits, the Court held the ailments were compensable. Under Section 44 of the Workmen’s Compensation Act, a presumption exists that an illness which supervenes during employment either arose out of or was aggravated by said employment. The burden to rebut this presumption shifts to the employer. The Republic failed to present substantial evidence to overcome this presumption. Ulibas’s demanding teaching duties, including prolonged speaking and preparation work, directly contributed to and aggravated her conditions, particularly her laryngitis and anemia-hypotension. It is sufficient that the employment contributed, even in a small degree, to the development or aggravation of the disease. The Court modified the award by increasing the attorney’s fees.