GR 43358; (May, 1978) (Digest)
G.R. No. L-43358. May 31, 1978.
PRESENTACION D. DELANA, petitioner, vs. WORKMEN’S COMPENSENCE COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.
FACTS
Catalino Delana, a City Superintendent of Schools, suffered a disabling illness (cerebral hemorrhage and pneumonia) on March 22, 1972, after attending a work-related program. He was hospitalized and filed a claim for disability compensation on April 30, 1974. Before its adjudication, he was compulsorily retired on February 14, 1973, and subsequently died on July 21, 1974, from conditions including Subarachnoid Hemorrhage. His widow, Presentacion Delana, filed a claim for death benefits. The Acting Referee awarded both disability and death benefits, finding the illnesses work-connected and that the death occurred within two years from the date the illness became compensable.
The Workmen’s Compensation Commission reversed the Referee’s decision, absolving the employer of liability. The Commission reasoned that the deceased was not disabled for labor at retirement, as he received his full salary, and that his death occurred over a year after retirement, thus breaking any causal connection.
ISSUE
Whether the petitioner is entitled to disability and death benefits under the Workmen’s Compensation Act.
RULING
Yes. The Supreme Court reinstated the award, setting aside the Commission’s decision. The legal logic centered on the presumption of compensability and the calculation of the compensable period. Under the Workmen’s Compensation Act, once an illness supervenes during employment, it is presumed to be work-related. The employer failed to rebut this presumption by not submitting any contrary evidence. The Court clarified that the compensable period for death benefits is counted from the date the illness becomes disabling, not from the date of retirement or death. Since Catalino Delana died within two years from March 22, 1972—the date his disability commenced—the death was compensable.
Furthermore, the Court corrected the computation of death benefits. The period of temporary total disability (33 1/7 weeks) should be deducted from the maximum 208-week death benefit period, not its monetary value. Using the correct formula (174 6/7 weeks at P22.50 weekly), the death compensation was increased to P3,934.28. The employer was ordered to pay the adjusted death benefits, full disability compensation, medical expenses, attorney’s fees, and administrative costs.