G.R. No. L-42624 February 29, 1988
ANA C. BARCENAS, petitioner, vs. THE WORKMEN’S COMPENSEMENT COMMISSION and REPUBLIC OF THE PHILIPPINES (Bureau of Standards), respondents.

FACTS

Sergio C. Barcenas, a Senior Commercial Agent of the Bureau of Standards, fell ill during an inspection trip in November 1972 and was diagnosed with diabetes mellitus and hypertensive vascular disease. Due to his deteriorating health, he took a leave of absence and subsequently retired on April 14, 1973. On July 16, 1973, he filed a claim for disability benefits under the Workmen’s Compensation Act, which the Bureau of Standards contested. Sergio died on March 13, 1974, from acute myocardial infarction and diabetes mellitus while his claim was pending. His widow, petitioner Ana C. Barcenas, then filed a claim for death benefits.
The Acting Referee awarded benefits to the petitioner. However, the Workmen’s Compensation Commission reversed this decision and dismissed the claim. The Commission reasoned that diabetes mellitus could not be considered work-related, attributing it instead to an individual’s personal eating and drinking habits. The petitioner elevated the case to the Supreme Court.

ISSUE

Whether the ailments (diabetes mellitus, hypertension, and myocardial infarction) that caused Sergio Barcenas’s disability and subsequent death are compensable under the Workmen’s Compensation Act.

RULING

Yes, the claim is compensable. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic is anchored on the established presumption of compensability under the Workmen’s Compensation Act. The Court had consistently ruled in prior cases that ailments such as diabetes mellitus, hypertension, and myocardial infarction are compensable. Following the precedent set in Flores v. Workmen’s Compensation Commission, the Court reiterated that it is sufficient for compensability if the employment contributed, even in a small degree, to the development or aggravation of the disease. The exact medical cause is not paramount.
Under Section 44 of the Act, a presumption exists that an illness which supervenes during employment either arose out of or was aggravated by that employment. This presumption shifts the burden of proof to the employer to disprove work-connection. In this case, the respondent Bureau of Standards failed to rebut this legal presumption. The Court further noted that, even under the subsequent more restrictive Labor Code, cardiovascular diseases like myocardial infarction are classified as work-related. Consequently, the Commission erred in denying the claim based solely on the non-occupational origin theory for diabetes. The award granted by the Acting Referee was therefore affirmed in its entirety.