G.R. No. L-43612, November 29, 1976
Cesar Dometita, petitioner, vs. Workmen’s Compensation Commission and Universal Textile Mills, Inc., respondents.

FACTS

Petitioner Cesar Dometita worked for respondent Universal Textile Mills, Inc. for nearly 14 years, his final position being a loom fixer. His work environment was characterized by constant standing, exposure to heat, and pervasive cotton and synthetic dust that he inhaled and that covered his eyes and face. In December 1973, he began experiencing symptoms including dizziness, headaches, vomiting, and loss of eyesight. He requested sick leave from the company clinic, but it was denied under threat of dismissal for absenteeism. He continued working until February 13, 1974, when, upon medical advice, he stopped. He was subsequently hospitalized and treated for optic neuritis and migraines by several physicians, incurring significant medical expenses.
Dometita filed a claim for compensation, which was dismissed by the Regional Office and later affirmed by the Workmen’s Compensation Commission (WCC). Both bodies ruled his illnesses had no causal relation to his employment. The petitioner sought a review, arguing his conditions were directly caused or aggravated by his arduous and hazardous working conditions over many years.

ISSUE

Whether the petitioner’s illnesses (optic neuritis and migraines) are compensable as arising out of or aggravated by the nature of his employment.

RULING

Yes. The Supreme Court reversed the WCC decision and granted the claim. The legal logic rests on two pivotal points under the Workmen’s Compensation Act. First, the presumption of compensability applies: an illness that supervenes during employment is presumed to be work-related. The burden to rebut this presumption shifts to the employer. Here, the respondent company failed to present substantial evidence to disprove the connection between Dometita’s debilitating conditions and his long-term exposure to dust, heat, and strain in the textile mill. The detailed description of his work environment and the onset of symptoms during employment sufficiently established that the illnesses were at least aggravated by his employment.
Second, and decisively, the respondent committed a fatal procedural lapse by failing to controvert the claim within the statutory period. This failure constitutes a waiver of all non-jurisdictional defenses, including the defense of non-compensability. Consequently, the employer is deemed to have accepted the compensability of the claim. The Court found the dismissal by the WCC to be erroneous as it ignored this waiver and the operative presumption of compensability. The employer was thus ordered to pay disability compensation, reimburse medical expenses, provide further necessary medical services, and pay attorney’s fees and costs.