GR L 45080; (November, 1979) (Digest)
G.R. No. L-45080 November 21, 1979
CONSTANCIA P. GACULA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Public Schools), WORKMEN’S COMPENSATION COMMISSION defunct and/or COMPENSATION APPEALS AND REVIEW STAFF, Office of the Secretary of Labor, Department of Labor, respondents.
FACTS
Petitioner Constancia P. Gacula was a public school teacher from November 1, 1939, until her retirement on October 1, 1970. Her duties involved teaching multiple subjects, preparing lesson plans and teaching aids during evening hours, attending seminars, and conducting home visitations that required hiking. During her employment, she developed several ailments, including incipient pulmonary tuberculosis (PTB), chronic rheumatoid arthritis, laryngitis, and hypotension-anemia, as certified by her physician, Dr. Alfredo A. Cadena. The physician stated these illnesses were a result of and aggravated by her employment and resulted in permanent total disability, advising her to retire.
On May 24, 1974, Gacula filed a claim for disability compensation benefits under the Workmen’s Compensation Act. The Acting Referee awarded her P6,000.00. However, the Workmen’s Compensation Commission, upon a motion for reconsideration filed by the Solicitor General, reversed the award and dismissed the claim. The Commission held there was no proof she was actually disabled from work, reasoning she stopped working due to optional retirement at age 63 and not due to her illnesses, and thus suffered no impairment of earning capacity.
ISSUE
Whether the Workmen’s Compensation Commission erred in dismissing Gacula’s claim for disability compensation benefits.
RULING
Yes. The Supreme Court reversed the Commission’s decision and reinstated the award. The legal logic is anchored on the statutory presumption of compensability under Section 44 of the Workmen’s Compensation Act. When an illness supervenes during employment, it is presumed to have arisen out of or been aggravated by such employment. The burden to rebut this presumption shifts to the employer. In this case, the respondent Bureau of Public Schools failed to present substantial evidence to overthrow this presumption. The Commission incorrectly placed the burden of proof on the claimant.
The Court emphasized that the Act is social legislation intended for the relief of workers, warranting a liberal interpretation in their favor. The fact of optional retirement does not negate compensability, especially when the medical evidence shows the illnesses were work-connected and led to disability. The Court cited precedents establishing that tuberculosis is compensable for teachers. Since the employer failed to controvert the claim within the statutory period and offered no incontrovertible proof that the illnesses were not work-related, the presumption became conclusive. Therefore, Gacula was entitled to disability compensation, reimbursement for medical expenses, attorney’s fees, and administrative costs.