G.R. No. L-43416. December 8, 1976.
Socorro J. Catibog (deceased), substituted by: Lauro Catibog, husband, Flordeliza de Joya and Consuelo A. Admana, sisters, petitioners, vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Public Schools), respondents.

FACTS

Socorro J. Catibog served the Bureau of Public Schools for 43 years, from 1932 until her disability retirement in 1974, holding positions from classroom teacher to District Supervisor. In July 1974, she began experiencing symptoms of hypertensive heart disease, hypercholesterolemia, and angina pectoris. Her condition seriously recurred on September 7, 1974, forcing her to stop working. Upon her physician’s recommendation, she applied for and was granted disability retirement effective December 20, 1974. She subsequently filed a claim for compensation benefits under the Workmen’s Compensation Act. The Acting Referee of the Department of Labor Regional Office No. 5 awarded the claim, finding the employer’s failure to seasonably controvert it resulted in a waiver of non-jurisdictional defenses and that a rebuttable presumption of compensability existed. However, the Workmen’s Compensation Commission reversed this decision and absolved the employer from liability.

ISSUE

Whether the illness and subsequent death of Socorro J. Catibog are compensable under the Workmen’s Compensation Act.

RULING

Yes, the claim is compensable. The Supreme Court reversed the decision of the Workmen’s Compensation Commission. The legal logic rests on the statutory presumption of compensability under the Workmen’s Compensation Act. When an illness supervenes during employment, it is presumed to be work-related or to have been aggravated by the employment. This presumption operates to relieve the employee from the burden of proving causation, shifting the burden to the employer to disprove the connection. In this case, the employer failed to present evidence to rebut this presumption. The Court emphasized that Catibog entered government service in good health and performed her duties for over four decades until her illness manifested and disabled her. Her work as an educator was mentally arduous, which could contribute to the development or acceleration of her hypertensive condition. Furthermore, her death on May 1, 1976, from coronary thrombosis and hypertension, just over a year after her disability retirement, strongly corroborated that her illness was work-connected and had already afflicted her during her employment. The fact of her disability retirement itself is indicative of the work-related nature of her incapacity. Consequently, the claim is within the purview of the Act. The Court awarded death and disability benefits, reimbursement for medical expenses, attorney’s fees, and administrative fees to her surviving heirs.