GR 45141; (January, 1981) (Digest)
G.R. No. L-45141 January 27, 1981
Petronila T. Cabalquinto vs. Republic of the Philippines (Bureau of Public Schools), et al.
FACTS
Petronila T. Cabalquinto, a public school teacher and Principal I, filed a claim for disability compensation on March 12, 1974, due to chronic muscular rheumatism, hypertension, and a weak heart, which she alleged were contracted or aggravated by her employment. The respondent, the Republic through the Bureau of Public Schools, was duly served with the notice but failed to file a timely controversion. The Acting Referee of Regional Office No. 4 rendered a decision on August 28, 1974, awarding Cabalquinto P6,000 in disability benefits. The respondent appealed this decision to the Workmen’s Compensation Commission.
The WCC reversed the Referee’s decision, absolving the respondent from liability. The Commission found that the claimant was not incapacitated for labor prior to her retirement. The petitioner sought review, contending the respondent’s appeal to the WCC was filed beyond the reglementary period, rendering the Referee’s decision final and executory.
ISSUE
Whether the Workmen’s Compensation Commission erred in absolving the respondent from liability for the petitioner’s disability claim.
RULING
Yes. The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award. The legal logic centers on the application of the disputable presumption of compensability under the Workmen’s Compensation Act. The record established that the petitioner entered employment in good health in 1932 and the subject ailments (chronic muscular rheumatism, hypertension, weak heart) manifested during her employment, specifically in 1971. This supervenience of illness during employment gives rise to the presumption that the claim is compensable.
Consequently, the burden of proof shifts to the employer to rebut this presumption by substantial evidence, proving the illness is not work-related or compensable. The respondent failed to present such evidence to overcome the presumption. The medical opinion of Dr. Alfredo A. Cadena, which stated the ailments were aggravated by her duties as principal-teacher, remained uncontroverted. Given this failure, the claim must be granted. The Court found it unnecessary to resolve the ancillary issue regarding the timeliness of the respondent’s appeal to the WCC, as the merits of the compensation claim were decisively established in favor of the petitioner under the governing legal presumption.