G.R. No. L-43344. September 29, 1976.
PASCUALA D. VDA. DE LARON, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Department of Health), respondents.

FACTS

Marcelo Laron was employed as a cook at the Doña Gregoria Memorial Hospital, a government-operated facility in Agoo, La Union. His duties involved preparing meals multiple times daily, exposing him to heat from firewood stoves, cleaning the kitchen, and performing other manual tasks. While employed, he experienced loss of appetite and abdominal pains, leading to his confinement at his workplace hospital from November 1 to 3, 1972. He was subsequently transferred to Baguio General Hospital, where he was diagnosed with stomach cancer. He died from this illness on May 24, 1973.
His widow, Pascuala D. Vda. de Laron, filed a claim for death benefits with the Workmen’s Compensation Commission. The Hearing Unit dismissed the claim for alleged lack of interest in submitting supporting affidavits, a dismissal affirmed by the Commission on review for insufficient evidence. The widow elevated the case to the Supreme Court, arguing the Commission disregarded established jurisprudence.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing the claim for death benefits arising from Marcelo Laron’s illness and subsequent death.

RULING

Yes. The Supreme Court reversed the Commission’s decision and awarded compensation. The legal logic rests on two pivotal principles under the Workmen’s Compensation Act. First, the employer’s failure to timely controvert the claim results in a waiver of non-jurisdictional defenses and constitutes an admission of compensability. The employer-hospital, through its own physicians, was fully aware of Laron’s illness from his initial confinement in November 1972. Despite this knowledge, the Department of Health never filed a requisite notice of controversion from that time until Laron’s death in May 1973. This failure forfeited its right to challenge the claim.
Second, the law establishes a rebuttable presumption that an illness which supervenes during employment is presumed to have arisen out of or been aggravated by said employment. The burden to disprove this causal link shifts to the employer. Here, the employer, having waived its defenses through non-controversion, could not rebut this presumption. Moreover, the Court found that the nature of Laron’s work—involving physical strain, exposure to heat, and mental pressure—could have contributed to a general weakening of his bodily resistance, facilitating the development of the malignant tumor. In compensation cases, probability, not medical certainty, is the standard for establishing the work-connection of an illness. Consequently, the claim was deemed compensable. Respondent was ordered to pay death benefits, burial expenses, and attorney’s fees.