GR L 23640; (May, 1968) (Digest)
G.R. No. L-23640 May 22, 1968
REMEDIOS MALUPA VDA. DE LAYAG, petitioner, vs. REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC WORKS), respondent.
FACTS
Petitioner Remedios Malupa Vda. de Layag filed a claim for death benefits under the Workmen’s Compensation Act for herself and her minor children following the death of her husband, Alberto Layag. Alberto Layag had been employed as a chief-cook on the tugboat M/V Chester of the Bureau of Public Works since 1948, after passing a pre-employment physical examination. His duties included marketing, cooking, setting tables, washing dishes, and occasionally cleaning the deck. He was hospitalized in 1949 and 1955 for various illnesses. On January 23, 1960, he was confined at San Lazaro Hospital for hemorrhagic fever. He was later admitted to North General Hospital from February 8 to March 12, 1960, for hypoplastic anemia and ascariasis, readmitted on March 9, 1960, and died on March 29, 1960, from thrombocytopenic purpura with cerebral hemorrhage and hypoplastic anemia. The Workmen’s Compensation Commission denied the claim, finding no causal connection between his death and his employment.
ISSUE
Whether the cause of Alberto Layag’s death was service-connected, thereby entitling his heirs to compensation benefits under the Workmen’s Compensation Act.
RULING
No. The Supreme Court affirmed the decision of the Workmen’s Compensation Commission. The Court held that the illness (thrombocytopenic purpura with cerebral hemorrhage and hypoplastic anemia) that caused Layag’s death was foreign to the nature of his work as a chief-cook. The Commission properly considered a medical study by its senior medical officer explaining the clinical causes of the disease, which it was authorized to do under its rules to inform itself on technical questions without being bound by technical rules of evidence. Since this finding was supported by substantial evidence, the statutory presumption under Section 43 of the Workmen’s Compensation Act that a claim falls within the Act’s provisions did not apply. The claim was denied.