GR 44221; (August, 1978) (Digest)
G.R. No. L-44221. August 31, 1978.
FEDERICO SEVILLA, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.
FACTS
Federico Sevilla served as a public school teacher and supervisor from 1929 until his optional retirement on December 4, 1972, at age 63. His duties as Supervisor I involved extensive travel to far-flung barrios, walking, crossing rivers, and working in all weather conditions on difficult terrain to evaluate schools and conduct seminars. He alleged that he became disabled and was forced to retire due to rheumatoid arthritis and diabetes mellitus, which he incurred and which worsened in the course of his employment starting September 10, 1966. Medical certifications confirmed his total permanent disability, and his employer’s report substantiated his claim. The Workmen’s Compensation Unit referee awarded compensation, finding his ailments work-connected.
The Workmen’s Compensation Commission reversed the referee’s decision. The Commission ruled that Sevilla’s ailments were not compensable, reasoning that diabetes mellitus is a hereditary metabolic disease and rheumatoid arthritis is a degenerative result of the aging process, not directly caused by his employment. The Commission dismissed the claim despite the referee’s findings of work-connection and the employer’s failure to effectively controvert the claim.
ISSUE
Whether the illnesses of Federico Sevilla are compensable under the Workmen’s Compensation Act.
RULING
Yes. The Supreme Court reinstated the referee’s award, setting aside the Commission’s decision. The legal logic is anchored on the established presumption of compensability under the Workmen’s Compensation Act. Once an illness supervenes during employment, it is presumed to be work-related or to have been aggravated by such employment. The burden shifts to the employer to rebut this presumption by substantial evidence.
The Commission erred in requiring a direct causal link. Jurisprudence, specifically Abana vs. Quisumbing, holds that it is sufficient that the employment contributed, even in a small degree, to the development or aggravation of the disease. The exact medical cause is not paramount. Sevilla’s arduous duties, involving constant travel and physical strain over decades, undoubtedly contributed to the aggravation of his conditions. The respondent employer, the Bureau of Public Schools, failed to present evidence to overthrow the statutory presumption and the factual findings of the referee regarding work-connection.
Therefore, the claim is compensable. The Court ordered the Republic to pay Sevilla P6,000.00 as disability compensation, P3,252.55 for medical expenses, attorney’s fees, and an administrative fee.