G.R. No. L-42774 February 28, 1979
MANILA TIMES PUBLISHING CO., INC., petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and NITTO P. ITONA, respondents.

FACTS

Nitto P. Itona was employed in the Promotions Department of Manila Times Publishing Co., Inc. His duties involved overtime work, special coverages, and exposure to the elements, leading to strain and stress. In September 1972, an x-ray examination revealed he was suffering from moderately advanced pulmonary tuberculosis. He reported his illness to his employer and received medication from the company physician in October and November 1972. The petitioner ceased its newspaper publishing operations upon the proclamation of Martial Law on September 21, 1972, but continued other business activities such as receiving printing jobs and leasing facilities. Itona filed a claim for disability benefits with the Workmen’s Compensation Unit. The Acting Referee awarded compensation, a decision affirmed by the Workmen’s Compensation Commission. The petitioner contested this, arguing the employer-employee relationship had terminated, the P8,000 settlement from a separate unfair labor practice case extinguished liability, and that the illness was not work-related.

ISSUE

The primary issue is whether the Workmen’s Compensation Commission correctly awarded disability compensation and medical reimbursement to Itona despite the cessation of the newspaper business and the prior monetary settlement.

RULING

The Supreme Court affirmed the Commission’s decision with modification regarding proof of medical expenses. The legal logic centered on the presumption of compensability under Section 44 of the Workmen’s Compensation Act. Since Itona’s illness supervened during his employment, it was presumed to have arisen out of or was aggravated by said employment. The burden to rebut this presumption shifted to the employer, and Manila Times failed to present evidence to discharge this burden. The Court rejected the argument that the employer-employee relationship ceased entirely after September 21, 1972, noting the corporation continued other business operations. The P8,000 payment received by Itona was explicitly for the settlement of an unfair labor practice case, covering salary increases and allowances, and was never intended to constitute compensation benefits for his disability. Therefore, it did not extinguish the employer’s liability under the Workmen’s Compensation Act. With no showing that Itona’s tuberculosis had been arrested or cured, he was entitled to the maximum disability benefit of P6,000.00. Reimbursement for medical expenses was also proper, subject to presentation of supporting receipts.