G.R. No. L-43080. January 31, 1979.
DIONISIA VDA. DE LOS SANTOS, for herself and in behalf of her minor children, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and SAN MIGUEL CORPORATION, respondents.

FACTS

Aniceto de los Santos was employed by San Miguel Corporation from 1940 until his termination on July 9, 1970, having worked as a forklift operator. He filed a claim for disability benefits on March 12, 1973, alleging he suffered from hypertension and related illnesses since December 1964, conditions he reported to his employer. Medical evidence, including an SSS certificate, diagnosed him with hypertensive cardiovascular disease and congestive heart failure, declaring him permanently and totally disabled as of July 9, 1970. During the pendency of his claim, Aniceto died on June 1, 1974. His widow, Dionisia Vda. de los Santos, amended the claim to seek both disability and death benefits for herself and her minor children.
The Acting Referee granted an award of P6,000 as disability benefits but denied death benefits, reasoning that Aniceto’s death occurred more than two years after his disability date. The decision emphasized that the employer’s failure to controvert the claim resulted in a waiver of non-jurisdictional defenses and an admission of compensability. However, the Workmen’s Compensation Commission reversed this award, dismissing the claim on grounds of lack of evidence and the claimant’s alleged failure to prove the illness was work-related.

ISSUE

Whether the Workmen’s Compensation Commission erred in reversing the Acting Referee’s award of disability compensation benefits to the heirs of the deceased employee.

RULING

Yes, the Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic rests on the established presumption of compensability under the Workmen’s Compensation Act. Once an illness supervenes during employment, as hypertension did here during Aniceto’s long tenure, the law presumes it arose out of or was aggravated by the employment. The burden shifts to the employer to rebut this presumption by substantial evidence. San Miguel Corporation failed to meet this burden; its non-controversion of the claim constituted a waiver of defenses and an admission of compensability. The Court found the medical evidence, including the SSS certificate and clinical findings, sufficient to establish the disabling illness. The employer’s unexplained failure to produce Aniceto’s medical records from company hospitals further weakened its position. Consequently, the disability benefits awarded by the Acting Referee were fully justified. The denial of death benefits was correct under Section 8 of the Act, as death occurred beyond the two-year period from the date of disability, but disability benefits from July 9, 1970, until death on June 1, 1974, were properly due. The Court ordered San Miguel to pay the P6,000 disability benefits, reimburse medical expenses, and pay attorney’s fees.