G.R. No. L-45484 April 8, 1988
ZOSIMO CAPACIO, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), respondent.

FACTS

Petitioner Zosimo Capacio was an elementary public school teacher in Barrio Matambong, Palapag, Northern Samar, rendering 33 years of service. He retired on August 13, 1974, at age 60, due to peptic ulcer, hypertension, and schistosomiasis. His ailments began on March 19, 1973, and persisted until his retirement. His assignment required a daily one-and-a-half-hour hike through rivers, creeks, and rough terrain infested with schistosoma parasites. Immediately after retirement, he filed a claim with the Workmen’s Compensation Unit and underwent medical examination, leading to hospitalization.
The Hearing Officer awarded Capacio compensation, finding his illnesses work-connected and noting the respondent’s failure to timely controvert the claim as required by law. However, the Workmen’s Compensation Commission reversed this award. The Commission held that the medical treatments and an EKG test occurred after his employment ceased, and it concluded he retired voluntarily to enjoy retirement benefits after long service, not due to a disabling illness.

ISSUE

Whether petitioner Zosimo Capacio is entitled to compensation benefits under the Workmen’s Compensation Act for his illnesses.

RULING

Yes. The Supreme Court reversed the Commission’s decision and reinstated the Hearing Officer’s award. The legal logic rests on two key principles under Act No. 3428 , the Workmen’s Compensation Act. First, Section 44 establishes a rebuttable presumption that an illness either arose out of or was aggravated by the employment. The burden to disprove this presumption shifts to the employer. Here, the respondent Bureau of Public Schools failed to present evidence to overcome this presumption. The Court found that the physical strain and hazardous conditions of Capacio’s assignment—daily hikes through schistosoma-infested areas—increased the risk of contracting his ailments, particularly schistosomiasis.
Second, the respondent lost its right to dispute liability due to its failure to comply with Section 45, which requires the employer to controvert the claim within 14 days from disability or 10 days from knowledge thereof. This failure results in a waiver of non-jurisdictional defenses and constitutes an admission of compensability. The Court emphasized that for compensation, only a reasonable work connection—not direct causal proof—is necessary. The illnesses occurred during employment, and their aggravation by his teaching duties was presumed. The post-retirement medical treatments did not negate this work-connection, as the ailments manifested and disabled him while he was still employed. Therefore, Capacio’s claim is compensable.