GR 49227; (April, 1980) (Digest)
G.R. No. L-49227 April 25, 1980
BUENAVENTURA J. BARGA, JR., petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (Commission on Audit), respondents.
FACTS
Petitioner Buenaventura J. Barga, Jr., employed with the Commission on Audit for nearly fourteen years as an auditing aide and supplies checker, filed a claim for compensation benefits for a perforated duodenal ulcer. His duties involved field inspections, delivering supplies over rough roads, and occasionally lifting heavy materials. He often missed meals and worked late hours due to urgent work demands. Medical records indicated he began experiencing ulcer symptoms in 1969. He was hospitalized in February 1975 for surgical intervention related to the ulcer.
The Government Service Insurance System (GSIS) denied his claim, ruling that a duodenal ulcer is not a listed occupational disease under Presidential Decree No. 626 and that he failed to prove the risk of contracting it was increased by his working conditions. The Employees’ Compensation Commission (ECC) affirmed this denial on March 15, 1978, prompting Barga to elevate the case to the Supreme Court via petition for review.
ISSUE
Whether the petitioner’s claim for compensation benefits for his duodenal ulcer is compensable under the applicable law.
RULING
The Supreme Court granted the petition and set aside the ECC decision. The legal logic hinges on the applicable law governing the illness onset. The Court noted that the petitioner’s symptoms began in 1969, which was prior to the effectivity of the New Labor Code’s compensation provisions on January 1, 1975. Consequently, the governing law was the old Workmen’s Compensation Act.
Under Section 44 of the Workmen’s Compensation Act, when an illness supervenes in the course of employment, a rebuttable presumption arises that the claim is compensable. The burden shifts to the employer to disprove either the causal link or aggravation by substantial evidence. The Court found that the respondents failed to present such evidence to rebut this presumption.
Crucially, the Court highlighted that the GSIS and ECC, in their own decisions, had admitted that the rigors of Barga’s work “aggravated his condition.” This admission was fatal to their defense. The Court reiterated established doctrine that for compensability, it is sufficient that the illness is aggravated by the nature of the employment, even if not directly caused by it. Since the respondents failed to rebut the presumption and even conceded aggravation, the claim must be granted. The GSIS was ordered to pay disability benefits, reimburse medical expenses, and pay attorney’s fees.