G.R. No. L-45017 June 25, 1980
ELINO A. VILLAFLOR, petitioner, vs. REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC SCHOOLS), WORKMEN’S COMPENSATION COMMISSION, defunct and/or THE SECRETARY OF LABOR and/or COMPENSATION APPEALS AND REVIEW STAFF, DEPARTMENT OF LABOR, respondents.

FACTS

Petitioner Elino A. Villaflor, a public elementary school teacher, retired on October 1, 1971, at age 60, upon his doctor’s advice. His medical history included pulmonary tuberculosis and hypertensive heart disease, with symptoms manifesting before 1970. His attending physician, Dr. Exequiel Santiago, reported in 1973 that the hypertensive heart disease was contracted “in line of duty” and rendered petitioner completely disabled from his work, which required mental and physical exertion. An Evaluating Committee of the Bureau of Public Schools also concluded the illness was incurred during service and recommended compensation.
The Acting Referee granted petitioner’s claim, awarding P6,000 in disability benefits. The respondent Bureau, through the Solicitor General, did not appeal but later filed a “Motion to Correct Decision,” contesting the computation of the compensation period. The Workmen’s Compensation Commission, upon review, set aside the Referee’s award and dismissed the case. It held petitioner failed to prove his pulmonary tuberculosis caused disability and found no record showing disability from hypertensive heart disease. It also opined that retirement under Republic Act No. 660 precluded disability benefits.

ISSUE

Did the Workmen’s Compensation Commission act with grave abuse of discretion in setting aside the final and executory award of the Acting Referee?

RULING

Yes. The Supreme Court reinstated the Referee’s award. The Commission’s decision constituted a grave abuse of discretion. Firstly, the Referee’s decision had become final and executory as no appeal or motion for reconsideration was filed by the respondent within the reglementary period. The subsequent “Motion to Correct Decision” was a mere subterfuge to revive the right to appeal, which had already lapsed. A final judgment can no longer be disturbed.
On the merits, the Commission erred in dismissing the claim. Under the Workmen’s Compensation Act, there is a rebuttable presumption that a claim is compensable if the illness supervened during employment. The respondent employer failed to overcome this presumption. Medical evidence, including the physician’s report and the findings of the Bureau’s own Evaluating Committee, established that petitioner’s hypertensive heart disease was work-related and caused his permanent total disability. Retirement does not negate compensability; an employee forced to retire due to a work-connected disability is entitled to compensation benefits. The award of P6,000 for permanent total disability was proper. The Court emphasized the Workmen’s Compensation Act is a social legislation that must be liberally construed in favor of labor.