G.R. No. L-43572 June 30, 1977
Catalina Evangelista, petitioner, vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Public Schools), respondents.

FACTS

Petitioner Catalina Evangelista was employed as a public school teacher from 1939 until her optional retirement on January 6, 1973, at age 61. She alleged that in 1972, she suffered from illnesses including rheumatic heart disease, congestive heart failure, mitral insufficiency, hypertension, and general body pain. She stopped working and went on sick leave starting October 5, 1972, until her retirement. Her claim for disability compensation was supported by a Physician’s Report and medical certificates from her attending physicians.
The Workmen’s Compensation Commission dismissed her claim. It found that her service records showed she remained employed and received her regular salary until retirement. The Commission concluded there was no loss of earning capacity prior to retirement and that her ailments, occurring at age 60, were attributable to the aging process, with no evidence of complications, hospitalization, or unpaid sick leave.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing petitioner’s claim for disability compensation benefits.

RULING

Yes, the Supreme Court reversed the Commission’s decision and awarded compensation. The legal logic rests on the application of the presumption of compensability under the Workmen’s Compensation Act, a social legislation to be liberally construed in favor of labor. The Court emphasized that the employer, the Bureau of Public Schools, failed to discharge its burden of proof. The employer did not controvert the claim, thereby waiving non-jurisdictional defenses. More critically, the employer did not present substantial evidence to disconnect the illnesses from her employment and destroy the legal presumption that the claim is compensable.
The Court found the Physician’s Report and medical certificates constituted substantial evidence of her disability beginning October 5, 1972. The fact that she was on paid sick leave and later retired did not negate the existence of a compensable disability that impaired her earning capacity, as the law compensates for the disability itself, not merely a loss of wages. The Commission’s reliance on her continued receipt of salary was erroneous; compensation is for the physical inability to work, which was substantiated by her sick leave. Consequently, the employer was ordered to pay disability compensation, medical expenses, attorney’s fees, and an administrative fee.