Facts:

Honorata M. Aguirre, the petitioner, was a permanent elementary grade school teacher employed by the Bureau of Public Schools in Tacloban City. On March 5, 1975, she filed a "Notice of Injury or Sickness and Claim for Compensation" with the Workmen's Compensation Unit at the Regional Office No. 9 in Tacloban City. Aguirre claimed that she was forced to cease her teaching duties due to an illness diagnosed as "meningoencephalitis, aseptic, acute and anemia moderate," which began on December 13, 1974. She was hospitalized at Bethany Hospital from December 25, 1974, to January 13, 1975, as certified by Dr. Salvador R. Abad, Jr. Following her hospitalization, Aguirre was compelled to take extended leaves of absence without pay. A notice regarding her claim was sent to the Office of the Solicitor General on March 19, 1975, but the employer only filed a controversion of the claim on May 16, 1975, well beyond the ten-day period mandated by law. The claim was ...

Facts:

Parties and Background

• Honorata M. Aguirre, a permanent elementary grade school teacher employed by the Bureau of Public Schools in Tacloban City, filed a claim for workers’ compensation.
• The claim arose from an alleged work-related illness that forced her to stop teaching.

Chronology of Events

• On December 13, 1974, petitioner ceased teaching due to health complications.
• She was diagnosed by Dr. Salvador R. Abad, Jr. with “meningoencephalitis, aseptic, acute” and “anemia, moderate.”
• Subsequently, she was confined at Bethany Hospital from December 25, 1974, to January 13, 1975, necessitating extended leaves of absence.

Submission of the Claim and Evidence

• On March 5, 1975, petitioner filed a “Notice of injury or sickness and claim for compensation” with the Workmen’s Compensation Unit, Regional Office No. 9, Tacloban City.
• Evidence presented included:
• A Medical Certificate dated February 6, 1975 from Dr. Abad confirming the diagnosis and period of confinement.
• A certification by Dr. Archimedes Jao detailing additional ailments such as “acute gastritis and polyneuritis” (dated March 31, 1975).
• A report by Dr. Ester De Paz-Abuyabor (dated October 3, 1975) documenting further symptoms and the resultant permanent partial disability (24% NSD).
• The claim was duly notified to the Office of the Solicitor General on March 19, 1975, but a controversion was only filed on May 16, 1975, beyond the prescribed period.

Proceedings and Initial Award

• The claim was set for several hearings with notices served to the claimant, the employer, and the Solicitor General.
• On October 30, 1975, Hearing Officer Fernando T. Collantes issued an award granting specific monetary benefits for:
• Compensation to the claimant.
• Reimbursement of medical expenses.
• Attorney’s fees.
• An administrative fee.

Points Raised by Respondents

• The respondent Commission argued that petitioner did not suffer any actual disability for work.
• The respondent employer contended jurisdiction issues arising from the applicability of the New Labor Code—specifically Article 206 (as amended by PD 622)—asserting that the claim should have been processed under provisions applicable from January 1, 1975.
• Reference was made to earlier cases (e.g., De Castro Jr. v. WCC) to support the argument that the claim should be evaluated under the New Labor Code rather than the Workmen’s Compensation Act.

Additional Observations

• The case rests on the principle that disability for compensation occurs when an employee’s capacity to work, and thereby his earning power, is impaired due to an injury sustained in the course of employment.
• Medical facts established that meningoencephalitis can cause significant mental and physical incapacities, particularly affecting a teacher’s ability to manage classroom duties.

Issue:

Compensability of the Claim

• Whether petitioner’s disability, which prevented her from teaching due to the diagnosed meningoencephalitis (and related ailments), is compensable under the Workmen’s Compensation Act.
• Whether the legal presumption of compensability applies despite the employer’s later argument and procedural delay in filing a controversion.

Procedural Timeliness and Jurisdiction

• Whether the employer’s failure to file a timely controversion has resulted in a tacit admission of compensability.
• Whether the transition to the New Labor Code affects the jurisdiction of the Workmen’s Compensation Commission over a claim that arose when the previous Act was in full force.

Causal Connection

• Whether petitioner’s illness, which led to a permanent and total disability, arose out of and was aggravated by the nature of her employment.
• The extent to which medical evidence supports the causal nexus between the work-related conditions and the resulting disability.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)