GR L 42087; (April, 1988) (Digest)
G.R. No. L-42087. April 8, 1988.
URSULA VDA. DE CLEMENTE, ET AL., petitioners, vs. THE WORKMEN’S COMPENSATION COMMISSION AND RATTAN ART AND DECORATIONS INC., respondents.
FACTS
Ricardo Clemente, a machine set-up man for Rattan Art & Decorations, Inc., died in his sleep on February 21, 1974, from acute cardiorespiratory failure. He was 49 years old. His widow and six minor children filed a claim for death benefits under the Workmen’s Compensation Act. The Acting Referee granted the claim, finding it compensable. The respondent employer moved for reconsideration, arguing the death was due to “bangungot,” a non-compensable cause. The Workmen’s Compensation Commission reversed the Referee’s decision, denying the claim on the grounds that the petitioners failed to establish a causal link between Clemente’s work and his death.
ISSUE
The sole issue is whether the cause of Ricardo Clemente’s death had a causal relation to the nature of his employment, making it compensable under the Workmen’s Compensation Act.
RULING
The Supreme Court granted the petition, reversing the Commission and reinstating the award. The legal logic rests on the application of the disputable presumption of compensability under the Workmen’s Compensation Act, a social legislation designed for the working man’s relief. When an illness or death supervenes during employment, the law presumes it arose out of or was aggravated by the employment. The burden to rebut this presumption by substantial evidence shifts to the employer. In this case, the employer failed to discharge this burden. The Court rejected the employer’s claim of “bangungot,” noting the death certificate stated acute cardiorespiratory failure. While the claimants did not prove a direct causal link, the Court emphasized that probability, not certainty, is the standard. Given the strenuous nature of Clemente’s work as a set-up man, the probability that it caused or aggravated his condition leading to heart failure could not be discounted. The Court further highlighted the liberal interpretation mandated for such laws, especially where the precise medical cause is complex, to fulfill the constitutional mandate of social justice. The employer’s failure to present substantial evidence to disconnect the death from the employment made the presumption of compensability conclusive.