GR L 38421; (December, 1979) (Digest)
G.R. No. L-38421 December 28, 1979
SOCIAL SECURITY SYSTEM, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and LEONORA H. LATUÑO, respondents.
FACTS
Leonora H. Latuño was employed by the Social Security System (SSS) starting March 3, 1959, rising to the position of Supervisor. In 1967, she began suffering from arthritis, which worsened by 1969. Due to this ailment, she wrote a letter requesting retirement and stopped working on June 1, 1969. On December 31, 1972, she filed a claim for disability compensation. The Acting Referee of Regional Office No. 4 granted her claim, awarding P6,000.00 as disability benefits. The SSS appealed, arguing the illness was not work-related and the claim was filed out of time. The Workmen’s Compensation Commission (WCC) affirmed the referee’s decision, prompting the SSS to elevate the case to the Supreme Court.
ISSUE
The primary issue is whether Latuño’s osteo-arthritis is compensable under the Workmen’s Compensation Act, considering its alleged connection to her employment and the timeliness of her claim.
RULING
The Supreme Court affirmed the WCC’s decision, upholding the award of disability compensation. The Court deferred to the factual findings of the referee and the Commission, which established that Latuño’s osteo-arthritis supervened during her employment with the SSS. Medical evidence, including a report and testimony from Dr. Arturo Fajardo, indicated her duties—involving constant pressure and exposure to air-conditioned rooms—aggravated her condition. Under Section 44 of the Workmen’s Compensation Act, an illness that occurs during employment gives rise to a disputable presumption that the claim is compensable. This presumption shifts the burden of proof to the employer to show the illness is not work-related. The SSS failed to present substantial evidence to rebut this presumption. Regarding timeliness, the Court ruled that failure to comply with the statutory period for filing under Section 24 is non-jurisdictional. Furthermore, applying Article 1144(2) of the Civil Code, a claim for compensation prescribes in ten years; Latuño’s claim, filed in 1972 for a 1969 disability, was well within this period. The Court modified the award only to include an additional P600.00 as attorney’s fees.