GR 45896; (August, 1980) (Digest)
G.R. No. L-45896 August 21, 1980
MARIA LACSON, petitioner, vs. THE SECRETARY OF LABOR, THE COMPENSATION APPEALS & REVIEW STAFF, THE WORKMEN’S COMPENSATION COMMISSION and THE DEVELOPMENT BANK OF THE PHILIPPINES, respondents.
FACTS
Felicidad Lacson Ramirez, employed by the Development Bank of the Philippines (DBP), stopped working on July 11, 1973, due to diabetes mellitus, pyelonephritis with uremia, and hypertension. She filed a compensation claim on August 17, 1973, but died on October 4, 1973, before its adjudication. Her mother, petitioner Maria Lacson, subsequently filed a claim for death benefits. The Acting Referee awarded compensation, finding the illnesses compensable.
The Workmen’s Compensation Commission, through Associate Medical Commissioner Herminia Castelo-Sotto, M.D., reversed the award. The Commission ruled the illnesses were “idiopathic” or inherent to the individual, with no medical evidence connecting them to her employment as a Loan Account Analyst. The Secretary of Labor, acting as head of the abolished Commission’s successor body, affirmed this decision. Petitioner thus elevated the case to the Supreme Court.
ISSUE
Whether the illnesses of the deceased, which led to her death, are compensable under the Workmen’s Compensation Act.
RULING
Yes, the illnesses are compensable. The Supreme Court reversed the decisions of the Commission and the Secretary of Labor. The legal logic rests on two pivotal principles under the Workmen’s Compensation Act. First, the employer, DBP, failed to timely and effectively controvert the claim as mandated by Section 45 of the Act. This failure results in a waiver of all non-jurisdictional defenses, including the ground that the illness is not work-related, and conclusively presumes the claim compensable.
Second, even on the merits, the presumption of compensability under Section 44 of the Act applies. The law presumes that a claim is compensable if the illness supervened during employment. The burden to rebut this presumption by substantial evidence shifts to the employer. Here, DBP relied solely on the medical opinion of Commissioner Sotto, who categorically stated the illnesses were inherent and not connected to her employment. The Court held that such a bare opinion is insufficient to overcome the legal presumption. Citing precedents like Abana vs. Quisumbing, the Court emphasized that it is enough that the employment contributed, even in a small degree, to the development or aggravation of the disease. The nature of the deceased’s work could have contributed to the aggravation of her conditions. Therefore, the award of death benefits, burial expenses, medical reimbursement, and attorney’s fees in favor of the petitioner was reinstated.