GR L 48252; (October, 1979) (Digest)
G.R. No. L-48252 October 30, 1979
DOMINGO ENRIQUEZ SR., petitioner, vs. REPUBLIC OF THE PHILIPPINES (NATIONAL IRRIGATION ADMINISTRATION), WORKMEN’S COMPENSATION COMMISSION and/or THE SECRETARY OF LABOR, respondents.
FACTS
Petitioner Domingo C. Enriquez Sr. was a Senior Security Guard for the National Irrigation Administration (NIA). He entered government service in 1952 and was in good health upon his employment with NIA in 1964. On February 19, 1973, while still employed, he suffered a stroke due to hypertension, resulting in paralysis of his right side, slurred speech, and total incapacity for work, as certified by his attending physician. He was also diagnosed with diabetes mellitus. He filed a claim for disability compensation under the Workmen’s Compensation Act.
The Acting Referee granted his claim, awarding disability benefits and reimbursement for medical expenses. However, the Workmen’s Compensation Commission (WCC) reversed this decision. The Commission absolved respondent NIA from liability, reasoning that hypertension and diabetes are “not disabling ailments” but are caused by degenerative changes due to the aging process and could be managed with proper food and medication. The Republic, through the Solicitor General, contended that hypertension is an ordinary disease of life not necessarily caused or aggravated by the petitioner’s employment.
ISSUE
Whether or not petitioner’s disability due to hypertension is compensable under the Workmen’s Compensation Act.
RULING
Yes, the disability is compensable. The Supreme Court reversed the WCC decision and reinstated the award. The legal logic rests on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. It is presumed that a claim falls within the Act’s provisions. Since the petitioner was in good health upon employment and the illness (hypertension) supervened during his employment, it is presumed to be work-connected and compensable.
The burden to rebut this presumption by substantial evidence shifts to the employer. Here, the respondent NIA failed to present such evidence. The Commission’s finding that the ailments were due to the aging process and not disabling did not constitute the required substantial proof to overcome the legal presumption. The Court emphasized that the Act is a social legislation designed to provide relief to workers, and its provisions must be liberally construed in their favor. The employer’s failure to successfully controvert the claim renders the presumption conclusive. Therefore, petitioner’s disability arising from hypertension, which supervened in the course of employment, is compensable.