GR 43638; (July, 1977) (Digest)
G.R. No. L-43638 July 29, 1977
CARLOS ESPINO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and VICTORIAS MILLING CO., INC., respondents.
FACTS
Petitioner Carlos Espino was employed by respondent Victorias Milling Company, Inc. from 1947 until his retirement on December 31, 1973, having risen to the position of boiling house technician. He filed a claim for disability compensation, alleging that he developed gouty arthritis and a duodenal ulcer due to the nature of his employment. The working conditions in the boiling house involved high temperatures, physical exertion, and irregular meal times. He underwent medical treatment and surgery, incurring significant expenses. The Unit Chief and Referee of the Department of Labor awarded compensation, finding the illnesses compensable as they were aggravated by work stress and conditions.
The Workmen’s Compensation Commission reversed this award, absolving the company of liability. The Commission relied on the opinion of a Compensation Rating Medical Officer, who stated that gout is an inborn error of metabolism and the ulcer was induced by anti-gout medication, concluding these had no service-connection. The Commission’s decision prompted Espino to elevate the case to the Supreme Court via certiorari.
ISSUE
Whether the illnesses (gouty arthritis and duodenal ulcer) suffered by petitioner are compensable under the Workmen’s Compensation Act.
RULING
Yes, the illnesses are compensable. The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award. The legal logic centers on the statutory presumption of compensability under the Workmen’s Compensation Act. Once an illness supervenes during employment, as it did here, the law presumes it arose out of or was aggravated by such employment. The burden to rebut this presumption by substantial evidence shifts to the employer.
The Court found that respondent company failed to discharge this burden. It merely relied on the medical officer’s non-categorical opinion, which did not constitute the required substantial evidence to overcome the legal presumption. In contrast, the evidence showed that Espino was physically fit upon annual company examinations until the illnesses manifested, which were subsequently aggravated by the stressful, warm, and physically demanding conditions of the boiling house. His early retirement at age 55 due to disability further supported the claim. Consequently, with the presumption unrebutted, the claim is meritorious. The Court ordered the company to pay disability compensation, reimburse medical expenses, and provide other requisite benefits.