G.R. No. L-43650. June 30, 1978.
EMILIANA VDA. DE PAILAGAO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and PHILIPPINE PACKING CORPORATION, respondents.

FACTS

The late Diego M. Pailagao was employed for thirty years by respondent Philippine Packing Corporation as a syrup department supervisor. His duties were physically demanding, involving the preparation and distribution of syrup, supervision of laboratory operations, checking freezers and sugar warehouses, and purifying water, which required him to hurry up and down long flights of stairs. He worked long hours, often from 2:00 AM until 5:00 or 8:00 PM. On July 15, 1967, he complained of hand numbness, a complaint that persisted. He received medical injections from the company physician but his condition deteriorated, manifesting numbness in his feet and shortness of breath. He was eventually hospitalized and died on July 22, 1967. The cause of death was diagnosed as auricular fibrillation and congestive heart failure due to arteriosclerotic cardiovascular disease.

ISSUE

The sole issue is whether the illness that caused Diego Pailagao’s death arose out of or was aggravated by the nature of his employment, making it compensable under the Workmen’s Compensation Act.

RULING

The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award of death benefits. The legal logic rests on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. When an illness 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 respondent corporation failed to discharge this burden. The Commission erroneously concluded that the heart condition was merely due to the employee’s age (58 years) and that his supervisory role was not strenuous. The Court found that the deceased’s job was not purely administrative but involved significant physical exertion and stress, as detailed in the facts. The nature of his work—long hours, demanding physical tasks, and pressure to meet production demands—could reasonably have contributed to or aggravated his cardiovascular disease. The respondent presented no convincing evidence to dissociate the illness from the employment conditions. Following established jurisprudence, the Court applied the principle that the Act is a social legislation to be liberally construed in favor of labor, and the presumption of compensability stands unrebutted.