GR 45017; (August, 1980) (Digest)
G.R. No. L-45017. August 6, 1980. ELINO A. VILLAFLOR, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), THE WORKMEN’S COMPENSMENT COMMISSION, defunct and/or The Secretary of Labor, and/or COMPENSATION APPEALS & REVIEW STAFF, Department of Labor, respondents.
FACTS
Elino A. Villaflor, a public school teacher, filed a claim for disability benefits under the Workmen’s Compensation Act. He alleged that he suffered from pulmonary tuberculosis and hypertension, illnesses aggravated by the nature of his employment. The Acting Referee of the Workmen’s Compensation Unit rendered a decision on December 17, 1974, awarding compensation benefits to Villaflor.
The Republic of the Philippines, through the Bureau of Public Schools, appealed this award to the Workmen’s Compensation Commission. On March 5, 1976, the Commission reversed the Referee’s decision and dismissed Villaflor’s claim. Villaflor then elevated the case to the Supreme Court via a petition for review. In a Decision promulgated on June 25, 1980, the Supreme Court initially denied the petition. Subsequently, Villaflor’s counsel, Atty. Felizardo Moreno, filed a letter-query dated July 22, 1980, which the Court treated as a Motion for Reconsideration.
ISSUE
Whether the Workmen’s Compensation Commission erred in reversing the award of compensation benefits to the petitioner-teacher.
RULING
The Supreme Court granted the Motion for Reconsideration, set aside the Commission’s judgment, and reinstated the original award of the Acting Referee. The legal logic is anchored on the presumption of compensability established under Section 44 of the Workmen’s Compensation Act. This provision states that if an illness supervenes during employment, it is presumed to have arisen out of or been aggravated by said employment, with the burden of proof to rebut this presumption shifting to the employer.
In this case, the petitioner successfully established that his illnesses of pulmonary tuberculosis and hypertension occurred or were aggravated during his tenure as a teacher. The employer, the Bureau of Public Schools, failed to present substantial evidence to overcome the legal presumption of compensability. The Commission’s reversal was therefore erroneous as it disregarded this statutory presumption. The Court’s ruling reinforces the principle that the Workmen’s Compensation Act is a social legislation designed to provide relief to workers, and its provisions must be liberally construed in favor of the employee. The award was reinstated with the modification that Atty. Felizardo R. Moreno was entitled to P600.00 as attorney’s fees for his legal services.