G.R. No. L-43471. September 30, 1978.
JOSE TORALDE, petitioner, vs. THE WORKMEN’S COMPENSATION COMMISSION and ORBE LINES, represented by ORLANDO TAN, Manager, respondents.

FACTS

Jose Toralde was employed as a bus driver by Orbe Lines starting in 1969. His work schedule was demanding, requiring him to work from 3:00 A.M. to 9:00 P.M., five days a week. Following the declaration of martial law in September 1972, his start time was adjusted to 4:00 A.M. In November 1973, a chest X-ray at Camarines Sur Provincial Hospital revealed he was afflicted with Pulmonary Tuberculosis (PTB). He underwent treatment for a month before returning to work. His condition persisted, leading to further medical treatment from various doctors in 1974. By July 1974, his illness had worsened, compelling him to cease work entirely for six months to undergo treatment.
On March 26, 1975, Toralde filed a claim for compensation with the Workmen’s Compensation Unit, which awarded him disability compensation, medical reimbursement, and attorney’s fees. However, the Workmen’s Compensation Commission reversed this award. The Commission concluded that Toralde stopped working not due to his PTB but because the bus he drove was involved in an accident. It further noted that he had been seen driving a passenger-jeepney after leaving his employment, which it interpreted as proof that his illness did not disable him from labor.

ISSUE

Whether the Workmen’s Compensation Commission erred in reversing the award, specifically in finding that Jose Toralde’s PTB did not constitute a compensable disability under the Workmen’s Compensation Act.

RULING

The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award. The Court held that the Commission’s findings were not supported by substantial evidence. The fact that Toralde occasionally drove a jeepney for his father-in-law after his separation did not conclusively prove he was gainfully re-employed or free from disability. Toralde explained this was a necessity to earn money for medicines, not an indication of full recovery or capacity for regular employment.
Legally, the nature of Toralde’s work—involving long hours, exposure to extreme temperatures, engine heat, and dusty, polluted air—created conditions that weakened his bodily resistance. Under the governing Workmen’s Compensation Act, an illness like PTB is presumed to be work-related or aggravated by employment when the working conditions are shown to increase the risk. This presumption became conclusive in this case, as the employer, Orbe Lines, failed to present substantial evidence to rebut it. The mere assertion that Toralde stopped work due to a bus accident, without proof, was insufficient to overcome the statutory presumption of compensability. Furthermore, the medical records and treatment history substantiated the existence and severity of his PTB. Consequently, the illness was deemed to have affected his earning capacity, making it compensable. The Court thus ordered the employer to pay the awarded compensation, medical expenses, attorney’s fees, and to provide necessary medical services.