GR 43689; (February, 1978) (Digest)
G.R. No. L-43689 February 28, 1978
BENIGNO GONZALES, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (National Irrigation Administration, Sibalom-San Jose Irrigation System), respondent.
FACTS
Petitioner Benigno Gonzales worked for the National Irrigation Administration from February 16, 1932, until his retirement on February 15, 1974, at age 64, holding the position of watermaster. His duties involved supervising dike construction and inspecting canals, requiring him to travel approximately 26 kilometers daily, often by bicycle or on foot, especially during rainy weather. On June 3, 1973, he suffered a stroke and was hospitalized. His attending physician diagnosed him with hypertension, cardiomegaly (atrial and ventricular), and myocardial ischemia. He filed a claim for compensation, and the acting referee awarded him disability benefits.
The respondent employer moved for reconsideration, and the Workmen’s Compensation Commission reversed the award. The Commission reasoned that Gonzales’s ailments were degenerative results of the aging process, not disabling or traceable to his employment. It emphasized there was no medical indication he was physically disabled at retirement and concluded he retired to avail of benefits under Republic Act No. 660 , not due to his illnesses.
ISSUE
Whether the Workmen’s Compensation Commission erred in reversing the award of compensation benefits.
RULING
Yes, the Supreme Court reversed the Commission’s decision. The legal logic rests on the doctrine of presumed compensability under the Workmen’s Compensation Act. When an illness supervenes in the course of employment, there is a rebuttable presumption that it arose out of or was aggravated by such employment. The claimant is relieved from proving causation, and the burden shifts to the employer to disprove this presumption by substantial evidence.
Here, Gonzales entered employment in good health and, after 42 years, was found afflicted with serious cardiovascular illnesses during his service. This undisputed fact triggered the presumption of compensability. The respondent employer failed to present any evidence to rebut this presumption. The Commission’s requirement for Gonzales to prove he was on sick leave or physically disabled at retirement erroneously placed the burden back on the claimant and ignored the statutory presumption. The Court noted that Gonzales’s hospitalization and subsequent delayed return to work in October 1973, as shown by the employer’s own report, indicated disability. Furthermore, his voluntary retirement under a circular requiring physical incapacity for efficient service supported the work-related nature of his disability. Consequently, the employer’s failure to discharge its burden rendered the presumption conclusive, entitling Gonzales to compensation.