Facts:

The case of Aproniano Alabat vs. Workmen's Compensation Commission and Republic of the Philippines (Bureau of Public Schools), with G.R. No. L-43942, revolves around Aproniano Alabat, a public school teacher who began his service in 1931 and later became a head teacher. Over the course of his employment, he developed multiple health issues including hypertension, hernia, appendicitis, and hepatitis. Due to these ailments, Alabat retired on November 2, 1973, when he was 63 years old, drawing a final salary of P4,404.00. On March 10, 1975, he filed a claim for compensation with the Workmen's Compensation Unit in Regional Office No. XIX, Tacloban City. Initially, the Hearing Officer found Alabat’s claim to be valid, awarding him P6,000. However, the Department of Education and Culture contested this decision, arguing that hypertension is merely a symptom and only becomes a disabling condition if complicated by other diseases. They contended that Alabat's claims were not

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Facts:

Background of the Claimant

• Aproniano Alabat, a public school teacher since 1931, later served as a head teacher.
• During his lengthy employment, he developed several illnesses including hypertension, hernia, appendicitis, and hepatitis.
• Owing to these illnesses, particularly the complications arising from hypertension, he was compelled to retire on November 2, 1973 at the age of 63.
• At retirement, his last drawn salary was at the rate of P4,404.00.

Filing and Initial Proceedings

• On March 10, 1975, the claimant filed a claim for compensation with the Workmen’s Compensation Unit, Regional Office No. XIX in Tacloban City.
• The Hearing Officer of this Regional Office found the claim compensable under the provisions of the Workmen’s Compensation Act.
• Subsequently, the Hearing Officer ordered the respondent, the Department of Education and Culture (now represented as part of Republic of the Philippines), to pay the claimant P6,000.00.

Motion for Reconsideration by the Respondent

• The Department of Education and Culture filed a motion for reconsideration.
• Their contention was that hypertension, being merely a symptom rather than a disease, should not independently qualify as a disabling condition—except when it is complicated.
• However, it remained undisputed that the claimant contracted all his illnesses during his employment with the Department.

Statutory and Evidentiary Framework

• Section 44 of the Workmen’s Compensation Act provides a presumption that illnesses contracted during employment are caused or at least aggravated by the work.
• This presumption shifts the burden on the employer to present substantial evidence to rebut the work connection.
• The case referenced Vargas vs. Philippine American Embroideries, Inc., which explains that once a preliminary link between the illness and employment is established, the employer must then disprove the compensability through substantial evidence.

Final Claims and Additional Entitlements

• The Court recognized that the claimant, having retired due to the disabling effects of his illnesses, was entitled not only to the disability compensation but also to the reimbursement of medical expenses provided proper receipts were furnished.
• The decision also considered ancillary financial awards including attorney’s fees and an administrative fee for the successor of the Workmen’s Compensation Commission.

Separate Concurrence

• Justice Makasiar, in his separate concurring opinion, emphasized that the respondent should additionally provide comprehensive medical, surgical, and hospital services.
• He underscored the right of the disabled employee under Section 13 of the Act to receive services that promote early restoration to his maximum physical capacity.
• This opinion reinforced the social justice guarantee reflected in both the 1935 and 1973 Constitutions and referenced Article 4 of the New Labor Code along with Article 1702 of the New Civil Code.

Issue:

Applicability and Scope of the Presumption under Section 44

• Whether the claimant’s illnesses, particularly the complicated hypertension, fall under the compensability presumption provided by the Act.
• If the respondent, as the employer, adequately rebutted or failed to rebut the presumption linking the claimant’s diseases to his employment.

Determination of Compensability

• Whether evidence of illnesses contracted during employment establishes a sufficient preliminary link to impose the employer's burden of proving no work connection.
• The effect of considering hypertension as a symptom versus a disabling disease within the framework of the Act.

Scope of Benefits Entitled to the Claimant

• Whether the claimant is entitled only to the fixed compensation benefit or also to additional reimbursements such as medical expenses.
• The appropriateness of awarding attorney’s fees and administrative fees within the compensation framework.

Broader Implications for Labor Protection

• Whether the interpretation of the Workmen’s Compensation Act should favor a broader protection of labor to align with constitutional and statutory mandates for social justice.
• The extent to which doubts in implementation and interpretation should be resolved in favor of the laborer.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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