GR L 43640; (November, 1979) (Digest)
G.R. No. L-43640 November 21, 1979
ANNA LAURIO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondents.
FACTS
Petitioner Anna Laurio served the respondent Bureau of Public Schools as a classroom teacher from October 1, 1959, and later as Principal I and II until June 26, 1974. She was in good health upon entry, having passed a physical examination. During her employment, she developed sinusitis, goiter, and chronic bronchitis. Her ailments began manifesting in 1966 (goiter) and 1970 (sinusitis), leading to a sick leave from October 1, 1973, to March 15, 1974. She subsequently transferred to the Commission on Elections. She filed a claim for compensation, which was dismissed by the Acting Referee and affirmed by the Workmen’s Compensation Commission. The Commission ruled her illnesses were not work-connected, attributing sinusitis to viral infection, goiter to iodine deficiency, and noting her bronchitis attack occurred while she was en route to resume work.
ISSUE
Whether petitioner’s illnesses of sinusitis, goiter, and chronic bronchitis are compensable under the Workmen’s Compensation Act.
RULING
Yes. The Supreme Court reversed the Commission’s decision. The legal logic rests on the rebuttable presumption of compensability under the Workmen’s Compensation Act. When an illness supervenes during employment, as here, where petitioner was healthy at hiring but developed the ailments after years of service, it is presumed to have arisen out of or been aggravated by the work. The burden shifts to the employer to disprove this connection by substantial evidence. The respondent employer failed to present any evidence to rebut this presumption, making it conclusive. The Court found the illnesses work-connected, noting that as a teacher and principal, petitioner was continuously exposed to chalk dust, which could cause or aggravate respiratory conditions like sinusitis and bronchitis. Furthermore, her sick leave period is considered part of her employment; an illness occurring during such leave is deemed to arise from employment. The employer was also barred from raising non-jurisdictional defenses, like non-compensability, as it did not controvert the claim initially. Petitioner was awarded disability benefits for temporary total disability from October 1, 1973, to March 15, 1974, based on 60% of her average weekly wage, plus reimbursement for medical expenses and attorney’s fees.