G.R. No. L-42592 September 28, 1984
FLORENCIA ANG LOPEZ, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and PHILIPPINE AMERICAN MANUFACTURING MARKETING CORPORATION, respondents.

FACTS

Florencia Ang Lopez was employed as a machine operator by Philippine American Manufacturing Marketing Corporation. On November 22, 1970, while at work, she suffered from body pains, weakness, fever, coughing, and breathing difficulty. She was examined by Dr. Triponia Avendana, who diagnosed her with pulmonary tuberculosis, cerebral thrombosis, and acute phylonephritis. Due to these ailments, she permanently stopped working. Her claim for disability compensation benefits was initially granted by the Workmen’s Compensation Section, Regional Office No. 4.
The respondent Workmen’s Compensation Commission reversed the regional office’s decision and dismissed the claim. The Commission held there was insufficient proof, reasoning that the physician’s report on tuberculosis lacked supporting laboratory or x-ray findings, a later 1975 x-ray did not show tuberculosis, and the finding of cerebral thrombosis was contradicted by an alleged ability to return to work.

ISSUE

Whether the evidence is sufficient to warrant an award of disability compensation benefits to the petitioner.

RULING

Yes. The Supreme Court reversed the Commission’s decision and reinstated the award. The Court found the Commission’s assessment of the evidence erroneous. The medical certificate from Dr. Avendana dated May 6, 1971, explicitly diagnosed pulmonary tuberculosis and noted a recent chest x-ray showed slight improvement, indicating a prior x-ray had been conducted. This certificate was prepared for Social Security System (SSS) sickness benefits in 1970-1971, not for the compensation claim filed later. The Court noted that SSS benefits require no proof of work-connection, so there was no motive for the physician to falsely certify tuberculosis.
Furthermore, an SSS chest x-ray from April 20, 1971, showed findings (“diffuse linear and nodular density”) compatible with tuberculosis, and a Philippine Tuberculosis Society examination from January 1971 noted a “suspicious density” also consistent with the disease. A 1975 certificate from Jose R. Reyes Memorial Hospital diagnosed “CVA thrombosis, old.” The Court emphasized that the regional office’s finding—that the petitioner was forced to stop and never returned to work—was supported by the records, contrary to the Commission’s unsupported assertion.
Applying the prevailing presumption of compensability under the Workmen’s Compensation Act, once an illness supervenes in the course of employment, it is presumed to arise out of or be aggravated by such employment. The petitioner’s ailments manifested during her employment. The respondent company presented no substantial evidence to rebut this legal presumption. Therefore, the claim is compensable.