G.R. No. L-43468. July 21, 1978.
Isabel Lopez Eliseo (Gualberto C. Eliseo), petitioner, vs. Workmen’s Compensation Commission and G & S Manufacturing Corporation, respondents.

FACTS

Isabel Lopez Eliseo worked as an embroidery reviser for G & S Manufacturing Corporation starting in 1972. Her duties involved handling various textiles and fabrics containing different chemicals. On December 14, 1973, she suffered a serious attack of her ailment at her workplace and was hospitalized. She had experienced prior dizziness, self-medicated at home. She was subsequently diagnosed with chronic granulocytic leukemia at multiple hospitals and died from the disease on April 28, 1975, during the pendency of her compensation claim.
Her claim for death benefits was dismissed by the Workmen’s Compensation Unit and affirmed by the respondent Commission. The dismissal was based on the finding that there was no substantial evidence to establish a causal relation between her leukemia and her employment. The Commission heavily relied on the attending physician’s report, which stated the causal relation to her employment was “undetermined.”

ISSUE

Whether the claimant’s illness of leukemia, which supervened during her employment, is compensable under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the decision of the Workmen’s Compensation Commission. The legal logic centers on the presumption of compensability established under the Workmen’s Compensation Act. Once it is shown that an illness supervened in the course of employment, a rebuttable presumption arises that the illness arose out of, or was at least aggravated by, the employment. The burden of proof then shifts to the employer to disprove this presumption by substantial evidence.
In this case, the claimant’s illness manifested and was diagnosed during her employment. The respondent corporation failed to discharge its burden of providing credible evidence to disconnect the leukemia from her work. The mere fact that the physician’s report marked the cause as “undetermined” is insufficient to rebut the legal presumption; it does not constitute the affirmative evidence required to show the illness was not work-related. The Court emphasized that the Workmen’s Compensation Act is social legislation, and all doubts in its implementation should be resolved in favor of the worker. Consequently, the presumption of compensability stood unrebutted, entitling the deceased’s heirs to death benefits, burial expenses, attorney’s fees, and an administrative fee.