G.R. No. L-45351 August 15, 1988
LOURDES DELGADO, petitioner, vs. REPUBLIC OF THE PHILIPPINES (BUREAU OF PUBLIC SCHOOLS) and WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Lourdes Delgado, a public school teacher, was rendered disabled from work on June 3, 1969, due to a diagnosed eye ailment of “cataract, mature, right and incipient, left.” She underwent an operation and subsequently filed a claim for compensation on July 29, 1974. The Acting Referee of the Workmen’s Compensation Commission rendered a decision on September 22, 1975, awarding her disability benefits and reimbursement for medical expenses. The Republic, through the Solicitor General, received this decision on September 25, 1975.
On November 14, 1975, the Republic filed a “Motion to Elevate Records for Relief of Judgment,” alleging an extraordinarily heavy workload caused the delay. The Workmen’s Compensation Commission gave due course to this motion and, on January 16, 1976, reversed the Referee’s award. The Commission ruled that cataract is a natural result of degeneration due to aging and is not compensable, dismissing the claim. Delgado filed the present petition for review on January 7, 1977, asserting the Commission’s decision was void for lack of jurisdiction, as the Republic’s motion was filed beyond the reglementary period.

ISSUE

The primary issues are: (1) whether the Workmen’s Compensation Commission acquired jurisdiction to review the Referee’s decision given the Republic’s tardy motion; and (2) whether Delgado’s cataract is compensable under the Workmen’s Compensation Act.

RULING

The Supreme Court granted the petition, reversing the Commission’s decision and reinstating the Referee’s award. On the jurisdictional issue, the Court found the Commission’s decision null and void. Under Section 49 of the Workmen’s Compensation Act, a party aggrieved by a Referee’s decision must file a petition for review within fifteen days from receipt. The Republic received the decision on September 25, 1975, but filed its motion only on November 14, 1975, clearly beyond the reglementary period. The Commission thus acted without jurisdiction in entertaining the belated motion and reversing the Referee’s decision, which had already become final and executory.
On the merits, the Court held the illness compensable. Under the governing Workmen’s Compensation Act, there exists a presumption that a claim is compensable if the illness supervened during employment. The burden is on the employer to rebut this presumption by substantial evidence. The respondent failed to discharge this burden. Its sole contention—that cataract is a natural result of the aging process—was a bare allegation unsupported by evidence. The Court noted that cataract is not exclusively caused by aging; it can be congenital, traumatic, toxic, or senile. The respondent did not prove that Delgado’s specific cataract was of a non-compensable type. Furthermore, the Court cited precedent establishing that even if aging is a contributing factor, the physical and mental exertions inherent in a long teaching career are equally contributing and aggravating causes, rendering the resulting disability compensable. The reinstated award of disability benefits and medical reimbursement was therefore affirmed.