GR L 43664; (July, 1990) (Digest)
G.R. No. L-43664 July 2, 1990
MELITONA GERSALINO, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, and REPUBLIC OF THE PHILIPPINES, respondents.
FACTS
Petitioner Melitona Gersalino, a public school teacher since 1962, filed a claim for disability compensation benefits in 1971 due to rheumatoid arthritis. She alleged her ailment was caused by prolonged standing and physical stress from her classroom duties. The Regional Office of the Department of Labor dismissed her claim in 1975, reasoning that only illnesses affecting earning power and depriving an employee of livelihood are compensable. Since she continued working and receiving her salary, she was deemed not entitled. Her ancillary claim for medical expense reimbursement was likewise dismissed.
Petitioner’s motion for reconsideration was denied. The Workmen’s Compensation Commission affirmed the dismissal on January 30, 1976, prompting this petition for review. The Commission noted that during all her sick leaves, petitioner was paid her full salaries, concluding compensation benefits were therefore unavailing.
ISSUE
Whether petitioner’s rheumatoid arthritis is compensable under the Workmen’s Compensation Act, as amended.
RULING
Yes, the ailment is compensable. Rheumatoid arthritis is recognized as an occupational disease associated with the nature of a public school teacher’s work. It is undisputed that petitioner’s illness supervened and was aggravated by her employment. Under Section 44 of the Workmen’s Compensation Act, this gives rise to the legal presumption of compensability, shifting the burden to the employer to disprove the claim. The respondent Commission failed to present evidence to rebut this presumption, relying merely on a bare pronouncement of non-compensability.
However, the Court clarified the nature of compensation benefits. Workmen’s compensation is designed to provide subsistence in lieu of wages when an employee’s earning capacity is impaired or destroyed. Since the factual finding showed petitioner received her full salaries during her sick leaves, she suffered no loss of earning capacity that would warrant disability income benefits. Nevertheless, entitlement to compensation is distinct from the right to medical benefits. Under Section 13 of the Act, the employer is required to defray medical and hospital expenses for compensable ailments. Therefore, while disability compensation is not payable due to the absence of wage loss, petitioner is entitled to reimbursement for her medical and hospital expenses duly supported by receipts. The decision under review was set aside, and the Commission was ordered to reimburse petitioner with legal interest from the date of her claim.