G.R. No. L-42294 December 28, 1979
Ildefonso Geraldo, Sr., petitioner, vs. Workmen’s Compensation Commission and Wack-Wack Golf and Country Club, respondents.

FACTS

Petitioner Ildefonso Geraldo, Sr., employed for 41 years as a timekeeper and gas station in-charge by respondent Wack-Wack Golf and Country Club, suffered a stroke diagnosed as “hypertension, with secondary hemiplegia” on January 7, 1972, at his home. The illness left him partially paralyzed, leading to his retirement in January 1972. In April 1972, the employer paid him P8,817.95, which it characterized as a humanitarian gesture and “full and complete payment” for any compensation benefits, though petitioner’s son testified it was a gratuity benefit from which medical expenses were deducted. Petitioner subsequently filed a claim for disability compensation.
The Acting Referee dismissed the claim, ruling the P8,817.95 payment constituted an advance satisfaction of compensation liability, exceeding the maximum P6,000.00 benefit. The Workmen’s Compensation Commission reversed this finding, correctly holding the payment was a gratuity for 41 years of service, not compensation, as the employer never pleaded payment as a ground for dismissal in its controversion. However, the Commission ultimately denied the claim on the merits, finding the illness not work-connected.

ISSUE

Whether petitioner’s illness is compensable under the Workmen’s Compensation Act.

RULING

Yes, the illness is compensable. The Supreme Court reversed the Commission’s decision. The legal presumption of compensability under Section 44 of the Workmen’s Compensation Act applies, as the illness of hypertension supervened during employment. The burden to rebut this presumption by substantial evidence shifts to the employer. Here, the employer’s evidence—an affidavit and a physician’s report opining the illness was not work-connected—was insufficient. Mere medical opinions, without more, cannot overcome the statutory presumption; they do not constitute the quantum of evidence required.
On the merits, the Court found the illness work-connected and aggravated by employment. Petitioner’s twin roles involved multiple responsibilities like issuing fuel, recording transactions, preparing time cards, and payrolls, which inherently generated stress and tension. Medical authority recognizes stress as a causative factor of hypertension. Therefore, the nature and demands of his job contributed to his condition. Consequently, respondent employer is ordered to pay petitioner P6,000.00 as disability benefits, reimburse medical expenses, pay attorney’s fees, and administrative fees.