GR 43352; (February, 1978) (Digest)
G.R. No. L-43352. February 28, 1978.
MANUEL ARIANZA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and CENTRAL AZUCARERA DE LA CARLOTA, INC., respondents.
FACTS
Petitioner Manuel Arianza was employed by respondent Central Azucarera de la Carlota, Inc. since 1960, having passed a pre-employment medical examination. His duties involved packing and piling bagasse, requiring strenuous physical effort and exposure to dust particles without protective masks, followed by work as a water tender in the fire-room where his lower body was immersed in hot water and his upper body exposed to cold. He began experiencing general bodily weakness in 1965, and by April 1972, his condition had become serious, leading to hospitalization. He was diagnosed with liver cirrhosis and advised complete rest.
The Workmen’s Compensation Unit awarded compensation, but the Workmen’s Compensation Commission en banc reversed this decision, dismissing the claim. The Commission’s reversal prompted the petitioner to elevate the case to the Supreme Court.
ISSUE
The sole issue is whether the petitioner’s illness, liver cirrhosis, is compensable under the Workmen’s Compensation Act.
RULING
The Supreme Court reversed the Commission’s decision and granted the claim. The legal logic centers on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. Once an illness supervenes during employment, it is presumed to have arisen out of or been aggravated by such employment. The burden then shifts to the employer to rebut this presumption by substantial evidence.
Here, the petitioner’s arduous work conditions—involving physical exertion, dust inhalation, and extreme temperature exposures—over a significant period, are deemed to have weakened his bodily resistance. The Court emphasized that it is not necessary for the employment to be the sole cause of the illness; it is sufficient that the working conditions contributed to its development or aggravation. The respondent employer failed to present credible evidence to disconnect the illness from the employment. The company physician’s opinion that heat and cold exposure were not etiologic factors was deemed insufficient to overcome the legal presumption, especially given the neglect in providing protective equipment. The Court cited analogous jurisprudence where illnesses not typically occupational were deemed compensable due to work conditions affecting health resistance.
Consequently, the respondent company was ordered to pay disability compensation, provide necessary medical services and appliances, reimburse medical expenses, and pay attorney’s and administrative fees.