G.R. No. L-38332. July 26, 1974.
LETICIA B. BELMONTE, et al., petitioners, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Posts), respondents.

FACTS

The petitioners, the widow and minor children of the deceased Eliseo Belmonte, sought death benefits under the Workmen’s Compensation Act. Eliseo Belmonte had been employed as a letter-carrier by the Bureau of Posts since 1945, later on a permanent basis from 1950 until his death on December 24, 1969. At the Barotac Nuevo post office, he performed the duties of a letter-carrier and, frequently, also acted as postmaster simultaneously. His duties as a letter-carrier involved strenuous physical activities such as collecting, sorting, and delivering mail on foot across the town and its barrios, often braving inclement weather. His acting postmaster duties added administrative and mental responsibilities.
The cause of death was established as “cerebrovascular hemorrhage due to hypertension.” The Workmen’s Compensation Commission, reversing the referee’s award, denied the claim. It accepted that the hypertension was not directly caused by the employment but concluded there was insufficient proof that the work aggravated the pre-existing condition to cause the fatal stroke, despite the referee’s findings on the strenuous nature of the deceased’s dual roles.

ISSUE

Whether the death of Eliseo Belmonte, caused by a cerebrovascular hemorrhage due to hypertension, is compensable under the Workmen’s Compensation Act, considering the claim that his employment aggravated his illness.

RULING

Yes, the death is compensable. The Supreme Court reversed the Commission’s decision and reinstated the referee’s award. The legal logic rests on two pivotal points. First, under Section 44 of the Workmen’s Compensation Act, when an illness supervenes during employment, there is a statutory presumption that it arose out of or was at least aggravated by such employment. This presumption is compensable unless the employer presents substantial evidence to rebut it. Here, the respondent employer failed to present any such substantial evidence to overcome this legal presumption.
Second, the Court found that the nature of Belmonte’s employment did in fact aggravate his hypertensive condition. The referee’s factual findings, which the Commission did not reject, detailed the “strenuous” and “rigorous” nature of his 24-year service, involving heavy physical exertion and mental strain from performing dual roles, especially during peak periods like Christmas. Medical testimony confirmed that heavy physical exertion and mental strain could cause blood pressure to rise and precipitate a hemorrhage in a hypertensive individual. The Commission’s own conjecture that “fatigue and exposure to too much heat could have triggered the stroke” inadvertently supported the aggravation theory. Therefore, the illness and resulting death were compensable under the Act, as the employment at least aggravated the pre-existing condition. The statutory presumption, unrebutted by the employer, conclusively established compensability.