GR 43363; (February, 1980) (Digest)
G.R. No. L-43363. February 21, 1980.
CELSO A. CABREIRA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (General Auditing Office), respondents.
FACTS
Petitioner Celso A. Cabreira, an employee of the General Auditing Office, filed a claim for disability compensation. He alleged that his illness—Benign Prostatic Hypertrophy with urinary tract infection—which required surgery and hospitalization from May 4 to June 17, 1973, was caused by his employment. He specifically claimed the condition resulted from continuously holding his urination due to work constraints. The Acting Referee of Regional Office No. 4 awarded him disability benefits and reimbursement for medical expenses. However, the respondent employer appealed to the Workmen’s Compensation Commission (WCC). The WCC reversed the referee’s decision and dismissed the claim, ruling that the illness was not due to his employment.
ISSUE
Whether the petitioner’s illness is compensable under the Workmen’s Compensation Act.
RULING
Yes, the illness is compensable. The Supreme Court reversed the WCC decision and reinstated the award. The legal logic rests on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. When an illness supervenes during employment, as it did here, a disputable presumption arises that the claim is compensable. The burden of proof then shifts to the employer to rebut this presumption by substantial evidence. The respondent employer failed to present any evidence to disprove the claim’s compensability. Moreover, the petitioner did not rely solely on the presumption; he presented evidence that his work, which prevented him from urinating regularly, at least aggravated his prostatic condition. Aggravation of a pre-existing illness due to employment conditions is compensable. The Court found the referee’s computation of temporary total disability benefits for 45 days and the reduced amount for medical expenses, based on proper evaluation and receipts, to be correct. Consequently, the employer was ordered to pay the awarded benefits, attorney’s fees, and administrative costs.