G.R. No. L-18241 December 27, 1963
SANTIAGO VICENTE, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and GONZALO PUYAT AND SONS, INC., respondents.

FACTS

Petitioner Santiago Vicente, a plant mechanic for respondent Gonzalo Puyat and Sons, Inc., suffered an accident on March 30, 1957, while in the course of his employment. He fell from a ladder, striking his chest and the back of his head against a cement wall. Although he regained consciousness after about an hour and continued working, he began exhibiting symptoms, including loss of memory, approximately two weeks later. He was subsequently hospitalized and diagnosed with cerebral arteriosclerosis and related conditions.
The respondent company and the Workmen’s Compensation Commission denied his claim for compensation. The Commission found that Vicente’s cerebral arteriosclerosis was a pre-existing condition, part of the natural aging process, and that his disability was due to the natural progression of this illness rather than the accident. It emphasized that he showed no immediate ill effects after the fall and continued working for a period, concluding there was no causal connection between the accident and his subsequent disability.

ISSUE

Whether the pre-existing illness of cerebral arteriosclerosis was aggravated by the work-related accident, making the resulting disability compensable under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the Commission’s decision and awarded compensation. The legal logic centers on the application of the presumption of compensability and a liberal interpretation of the Workmen’s Compensation Act as social legislation.
The Court held that the Commission erred in dismissing the claim simply because the illness was pre-existing and no outward injury was immediately manifest. Under Section 2 of the Act, an illness aggravated by the nature of employment is compensable. The Court applied the established principle that where an injury is sustained in the course of employment, a resulting disability is presumed to have arisen out of that employment. This presumption was not overcome by the employer’s evidence.
The Court reasoned that the absence of immediate visible injury does not preclude the existence of internal damage or the aggravation of a latent condition. The temporal sequence was critical: Vicente was healthy and performing his duties for five years prior to the severe fall, after which he rapidly developed debilitating symptoms. Medical authorities cited in the decision support that a severe fall or strain can excite or aggravate a pre-existing arteriosclerotic condition, leading to disability. The Act must be liberally construed in favor of the worker to fulfill its remedial purpose. Therefore, the accident aggravated his pre-existing condition, making the disability compensable.