G.R. No. L-23489 March 27, 1968
JULIAN ABANA (Deceased), Substituted by Arcadia Vda. de Abana, et al., petitioner, vs. FRANCISCO QUISUMBING, respondent.

FACTS

The petitioner, Julian Abana, was employed as a taxi driver by respondent Francisco Quisumbing, proprietor of Dollar Taxi, since February 13, 1952, after passing a physical examination. On August 21, 1958, Abana suffered a heart attack at home after work and was confined at the Philippine General Hospital for five days, diagnosed with “congestive heart failure, hypertensive.” After recovery, he returned to work and informed management of his illness. In 1959, he had another heart attack while driving. His heart ailment recurred often, requiring check-ups and treatment, and prevented him from working, though he reported each recurrence to management and requested sick or vacation leave with pay, which was never granted (only small “vales” were given). Despite the employer’s knowledge of Abana’s permanent total incapacity for labor, no sickness benefits or medical reimbursement were provided. By January 1961, due to deteriorating health, Abana could no longer work. The Hearing Officer awarded compensation, but the Workmen’s Compensation Commission reversed and dismissed the claim. During the appeal, Abana died and was substituted by his heirs.

ISSUE

Whether or not the petitioner is entitled to disability benefits under the Workmen’s Compensation Act for the heart ailment contracted during his employment.

RULING

Yes, the petitioner is entitled to benefits. The Supreme Court reversed the Commission’s decision. The nature of driving a taxi in Manila causes severe strain and tension that aggravates a heart condition. Since the ailment first occurred in 1958 during employment, it was at least aggravated by his work. Under the Workmen’s Compensation Act, it is sufficient that employment contributed, even in a small degree, to the development of the disease, and the claimant need not prove causation to the point of demonstration—probability is enough. Furthermore, Section 44 of the Act establishes a presumption that an illness supervening during employment arose out of or was aggravated by it, shifting the burden of proof to the employer to disprove the connection, which the respondent failed to do. The defense of prescription was rejected because the respondent had actual knowledge of the illness each time Abana reported it and requested leave, making formal notice superfluous. The Workmen’s Compensation Act, as social legislation, must be liberally construed. The award by the Hearing Officer (P3,057.60 as compensation, P500.00 for medical expenses, and continued medical services) was reinstated in favor of Abana’s heirs.