GR 48122; (February, 1989) (Digest)
G.R. No. L-48122 February 21, 1989
VISIA REYES, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public School and the Workmen’s Compensation Commission), respondents.
FACTS
Petitioner Visia Reyes was employed as an elementary school teacher by the Bureau of Public Schools for twenty-six years. In May 1974, her attending physician, Dr. Pedro J. Castro, diagnosed her with rheumatoid arthritis and hypertension. The physician attributed these illnesses to her working conditions, specifically her frequent exposure to floods while wading to school and conducting classes in flooded classrooms. In a medical report dated January 1975, Dr. Castro stated she was no longer physically fit for service and was indefinitely disabled, qualifying for retirement.
Consequently, at age 52, petitioner applied for and was granted optional retirement under Commonwealth Act No. 186 , effective July 1974, based on physical incapacity. Seven months after ceasing work, in March 1975, she filed a claim for disability compensation benefits under the Workmen’s Compensation Act. Her claim was denied by the Workmen’s Compensation Unit and subsequently by the Workmen’s Compensation Commission (WCC). The WCC ruled that her illnesses, while surfacing during employment, did not disable her from performing her work during her employment period, as she stopped working due to optional retirement rather than proven disability.
ISSUE
Whether petitioner is entitled to disability compensation benefits under the Workmen’s Compensation Act for her rheumatoid arthritis and hypertension.
RULING
Yes. The Supreme Court reversed the WCC decision and awarded disability compensation benefits to petitioner. The legal logic rests on the application of the doctrine of presumed compensability under Section 44 of the Workmen’s Compensation Act. This doctrine establishes a rebuttable presumption that an illness which supervenes during employment arises out of or is aggravated by such employment. The burden to disprove this presumption with substantial evidence shifts to the employer.
In this case, the Bureau of Public Schools failed to present any evidence to controvert petitioner’s claim or to rebut the statutory presumption. The WCC’s denial was based on an erroneous premise that petitioner was not disabled during employment. The Court clarified that her optional retirement itself, granted on the specific ground of physical incapacity as certified by her physician and confirmed by a government committee, constituted sufficient proof of disability. The approval of her retirement application legally presupposed a finding that she was physically incapacitated to render efficient service. Furthermore, the employer’s failure to contest the claim within the statutory period constituted a waiver of defenses and an admission of compensability. Therefore, the presumption of compensability stood unrebutted, entitling petitioner to benefits.