G.R. No. L-45694 December 18, 1979
Brigida Reyes, petitioner, vs. Workmen’s Compensation Commission and Republic of the Philippines (National Irrigation Administration), respondents.

FACTS

The petitioner, Brigida Reyes, filed a claim for death compensation following the demise of her husband, Mariano Reyes, who was employed as a carpenter by the National Irrigation Administration (NIA). The deceased was found dead in the project bunkhouse on July 4, 1973. The death certificate, issued by the project physician, listed the cause of death as hemorrhagic pancreatitis, with “over fatigue” noted as a contributing condition. Evidence presented during the hearing established that Mariano Reyes worked overtime, including until midnight on the day before his death, in the construction of a shed and swimming pool at the Pantabangan project site.
The Hearing Officer of Regional Office No. 1 awarded death benefits to the widow and her minor children. However, the Workmen’s Compensation Commission (WCC) reversed this decision on appeal. The WCC dismissed the claim, ruling that the illness which caused death was not shown to have been caused or aggravated by the deceased’s employment. The Commission’s reversal prompted the petitioner to elevate the case to the Supreme Court via a petition for review.

ISSUE

The central issue is whether the death of Mariano Reyes, due to hemorrhagic pancreatitis, is compensable under the Workmen’s Compensation Act, considering the presumption of compensability for illnesses supervening during employment.

RULING

The Supreme Court reversed the decision of the Workmen’s Compensation Commission and reinstated the award of death benefits. The Court anchored its ruling on the legal presumption of compensability established under Section 44 of the Workmen’s Compensation Act. It is undisputed that the fatal illness supervened during the period of Mariano Reyes’s employment with the NIA. Consequently, a disputable presumption arose that the claim was compensable, relieving the claimant of the burden to prove causation. The burden then shifted to the employer, the NIA, to present substantial evidence to rebut this presumption by proving that the illness was not work-related or aggravated by the employment.
The Court found that the NIA failed to discharge this burden. On the contrary, the evidence bolstered the claim’s compensability. The death certificate explicitly cited “over fatigue” as a contributing factor. Testimonial evidence confirmed that the deceased worked overtime, a fact admitted even by the NIA’s own witness, the Camp Superintendent, who believed the death was connected to his work. The nature of his duties as a carpenter, involving hard labor and extended hours, directly supported the conclusion that his work conditions aggravated or precipitated his fatal condition. Therefore, the legal presumption of compensability remained uncontroverted. The Court affirmed the Hearing Officer’s computation of death benefits, ordering the NIA to pay the petitioner the sum of P5,722.00 as compensation, P200.00 for burial expenses, plus attorney’s and administrative fees.