GR 43512; (May, 1978) (Digest)
G.R. No. L-43512 May 11, 1978
ROSALIA VDA. DE RANDOY, petitioner, vs. THE WORKMEN’S COMPENSATION COMMISSION and UNIVERSAL TEXTILE MILLS, INC., respondents.
FACTS
Bonifacio Randoy, employed as a painter by Universal Textile Mills, Inc., died in his sleep on December 13, 1974, due to congestive heart failure. His widow, Rosalia Vda. de Randoy, filed a claim for death benefits under the Workmen’s Compensation Act. The employer, Universal Textile Mills, controverted the claim, asserting that the death was not service-connected.
The Acting Referee dismissed the claim, citing the petitioner’s failure to present a death certificate or physician’s report to establish a causal link between the employment and the death. The Workmen’s Compensation Commission affirmed this dismissal on appeal. The Commission reasoned that the records failed to show any prior heart complaint related to his work and that death occurred at home while asleep, thus concluding the death did not arise out of or in the course of employment.
ISSUE
Whether the death of Bonifacio Randoy due to congestive heart failure is compensable under the Workmen’s Compensation Act.
RULING
Yes, the death is compensable. The Supreme Court reversed the Commission’s decision, applying the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. The legal principle is that once an illness, like congestive heart failure, supervenes during employment, it is presumed to have arisen out of or been aggravated by such employment. The burden to rebut this presumption by substantial evidence shifts to the employer.
In this case, the fact that Randoy died while in the employ of the respondent triggered this presumption. The Court found that the employer failed to present substantial evidence to overcome it. Notably, the Commission’s own finding that the deceased had no prior history of cardiac ailments was deemed to strengthen, not weaken, the presumption that the fatal heart attack was work-connected or aggravated. The Court cited controlling jurisprudence, including Talip v. Workmen’s Compensation Commission, which holds that the absence of a known pre-existing condition reinforces the presumption of compensability when a fatal attack occurs during employment. Consequently, the claim was granted, and the respondent was ordered to pay death benefits, burial expenses, attorney’s fees, and administrative costs.