GR 47075; (April, 1981) (Digest)
G.R. No. L-47075. April 8, 1981.
ERLINDA P. VILLASAN, ARMANDO VILLASAN and ALFREDO VILLASAN, petitioners, vs. REPUBLIC OF THE PHILIPPINES (Department of Health) Malaria Eradication Service, respondents.
FACTS
The deceased Apolinar Villasan was employed as an Epidemiological Aide with the Malaria Eradication Service from 1961 until his death on July 8, 1974, due to “irreversible shock secondary to severe hemorrhage and bleeding peptic ulcer.” His heirs filed a claim for death benefits under the Workmen’s Compensation Act. The employer, through the Solicitor General, controverted the claim based on a medical committee finding of no work-connection. The Acting Referee dismissed the claim, adopting a physician’s report that the illness was not work-related. Petitioners, initially without counsel, filed a motion for extension to seek reconsideration, which was denied based on a Department Order disallowing extensions. Their subsequent motion for reconsideration was also denied, and the Workmen’s Compensation Commission dismissed their appeal for being filed out of time, refusing to acquire jurisdiction.
ISSUE
Whether the Workmen’s Compensation Commission erred in dismissing the appeal on a technicality and whether the claim for death benefits is compensable.
RULING
Yes. The Supreme Court set aside the Commission’s decision. On procedural grounds, cases should be decided on their merits, not on technicalities, especially under the liberal construction mandated in favor of labor. On substantive grounds, the claim is compensable. Under Section 44(1) of the Workmen’s Compensation Act, when an illness supervenes during employment, a disputable presumption arises that it arose out of or was aggravated by the work. This presumption shifts the burden to the employer to disprove the claim by substantial evidence. The employer here failed to overthrow this presumption. The medical report relied upon by the Referee was insufficient, as a physician’s opinion cannot prevail over the legal presumption. Conversely, a sworn medical certificate from another doctor stated the peptic ulcer was acquired due to the deceased’s failure to eat on time during field trips, a condition inherent to his work. The nature of his duties, involving constant travel and irregular meals, supported this causal connection. Thus, the death is compensable. Petitioners were awarded P6,000.00 as death benefits, P77.43 for medical expenses, and P200.00 for burial expenses, subject to the Act’s limits.