G.R. No. L-43696 April 22, 1977
Ireneo Francisco, petitioner, vs. Workmen’s Compensation Commission and Republic of the Philippines (Bureau of Public Schools), respondents.

FACTS

The petitioner, Ireneo Francisco, sought death benefits under the Workmen’s Compensation Act following the death of his wife, Aida Madarcos Francisco, a public school teacher in Caluya, Antique, for about twelve years. She died on October 19, 1974, and the attending physician certified the cause of death as “post eclampsia.” During her employment, the deceased teacher was assigned to a school located on elevated ground, requiring her to hike and climb daily. She had complained of headaches long before her death and, in 1974 while pregnant, consulted a rural health physician who diagnosed her with hypertension. She continued working and was later hospitalized, where she died.
The Acting Referee of the Labor Provincial Office initially granted the claim. However, the respondent Workmen’s Compensation Commission reversed this decision on appeal, ruling that the ailment of post eclampsia had no causal relation to her employment as a teacher. The Commission’s denial prompted this petition for review.

ISSUE

Whether the respondent Workmen’s Compensation Commission erred in denying the claim by finding no causal connection between the deceased teacher’s fatal ailment (post eclampsia) and the nature of her employment.

RULING

The Supreme Court reversed the decision of the Workmen’s Compensation Commission. The Court held that the Commission failed to respect the presumption of compensability established under the Workmen’s Compensation Act. This legal presumption operates when an illness or death supervenes during employment, and the burden to disprove causation shifts to the employer. The respondent Bureau of Public Schools failed to present substantial evidence to rebut this presumption.
The Court explained the medical linkage between the deceased’s work conditions and her fatal ailment. Citing medical authorities, it noted that eclampsia, particularly post eclampsia occurring after delivery, is associated with hypertension (high blood pressure). Hypertension, in turn, is frequently found in individuals under emotional strain or engaged in strenuous physical exertion. The deceased’s employment involved significant physical demands, including daily hikes and climbing to an elevated school, and mental stresses from teaching duties such as lesson preparation and classroom instruction. These work-related physical and mental strains could have caused or, at the very least, aggravated her hypertensive condition, which culminated in fatal post eclampsia. Therefore, her death was compensable. The Court reinstated the award of death benefits, medical expenses, attorney’s fees, and administrative costs.