GR 43570; (October, 1978) (Digest)
G.R. No. L-43570 October 30, 1978
MACARIA ORELLANA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, LA SUERTE CIGAR & CIGARETTE FACTORY INC. & ROYAL GROUP INC., respondents.
FACTS
The petitioner, Macaria Orellana, began working for respondent La Suerte Cigar & Cigarette Factory Inc. in 1957 as a packet maker and later as a cellophaner. Her duties required her to sit in front of an electrically heated iron block. In 1964, she suffered an epileptic attack at work and was treated at the factory clinic. Due to her condition, she was transferred to a “reject section.” However, her illness worsened, and on October 5, 1968, she was compelled by the company physician to stop working entirely due to epilepsy.
On March 31, 1975, Orellana filed a compensation claim. The Hearing Officer awarded her disability benefits. The respondent employer received this decision on October 22, 1975, but filed a motion for reconsideration only on November 21, 1975, which was 30 days later and thus beyond the reglementary period. The motion was denied for being filed out of time, rendering the Hearing Officer’s award final. Despite this finality, the respondent employer appealed to the Workmen’s Compensation Commission, which reversed the award, ruling the illness was not compensable.
ISSUE
Whether the petitioner’s illness of epilepsy is compensable under the Workmen’s Compensation Act.
RULING
Yes, the illness is compensable. The Supreme Court reversed the Commission’s decision. The legal logic proceeds from two key points. First, under the applicable Workmen’s Compensation Act, when an illness supervenes during employment, it is presumed to be work-related and thus compensable. This presumption is jurisprudentially established. Second, and more critically, the petitioner did not merely rely on this presumption. She presented sufficient evidence to establish a causal connection between her employment and her illness. Her work as a cellophaner exposed her to an electrically heated iron block, and her epileptic attack first occurred at the workplace in 1964, necessitating a clinic visit. The progression of her condition, ultimately forcing her to stop work in 1968, was documented. Therefore, the evidence positively demonstrated that her epilepsy was caused or aggravated by her employment conditions. Consequently, the Court reinstated the Hearing Officer’s award, ordering the respondent employer to pay P6,000.00 as disability compensation, P600.00 as attorney’s fees, and P61.00 as an administrative fee.