GR 46263; (October, 1978) (Digest)
G.R. No. L-46263 October 30, 1978
JESUS RAMOS, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and the REPUBLIC OF THE PHILIPPINES (Department of Public Highways), respondents.
FACTS
Petitioner Jesus Ramos was employed as an auto-mechanic by the Bureau of Public Highways from 1930 to 1941 and again from 1946 until his retirement on September 8, 1973. On June 16, 1974, after retiring, he filed a claim for disability benefits under the Workmen’s Compensation Act due to “pulmonary tuberculosis, bilateral, chronic, hypertension, essential,” which he alleged was contracted and aggravated during his employment. The respondent employer controverted the claim, arguing the illness was not work-related. The acting referee and subsequently the Workmen’s Compensation Commission denied the claim for “insufficiency of evidence,” noting a perceived contradiction between his claim of disability and his continuous service record up to retirement.
ISSUE
Whether petitioner Jesus Ramos is entitled to disability benefits under the Workmen’s Compensation Act for his illness.
RULING
Yes. The Supreme Court reversed the Commission’s decision and awarded benefits. The legal logic is anchored on the unrebutted presumption of compensability under the Workmen’s Compensation Act. Once an illness supervenes during employment, it is presumed to be work-related. The employer failed to present substantial evidence to overthrow this presumption. Petitioner substantiated his claim with a physician’s report, service record, approved retirement documents, and certified copies of multiple sick leave applications from 1956 to 1966. These leaves, taken for his ailments, demonstrated the illness’s existence and its impact during his employment. His voluntary retirement at age 60, below the compulsory age of 65, further indicated physical incapacity, as such retirement is permitted only for medical incapacity. The Court emphasized that the Act is social legislation, interpreting doubts in favor of the worker. Probability, not absolute certainty, is the standard of proof. The Commission erred in dismissing the claim based on a perceived inconsistency; continuous service does not negate the presence of a disabling illness managed through intermittent sick leaves. Thus, petitioner is entitled to maximum disability benefits, attorney’s fees, medical reimbursement, and continued medical services.