Case Digest (G.R. No. L-42893)
Facts:
The case involves Leopoldo Ayuso (petitioner) against the Workmen's Compensation Commission and White Ways, Inc. (respondents). The events leading to the case began when Ayuso filed a claim for compensation benefits on May 16, 1973, with the Acting Referee of the Regional Office No. IV, Department of Labor, in Manila. Tragically, while awaiting a decision on his claim, Ayuso passed away on August 15, 1975. Following his death, his wife, Apolonia Bautista, was substituted as the petitioner in this case. Ayuso had been employed by White Ways, Inc. as a laborer from 1970 until August 31, 1972, earning a daily wage of P9.00. His job involved menial tasks such as cleaning toilets and making repairs in comfort rooms. Prior to his employment with White Ways, he worked for a sister company, "Better Buildings," from 1965 to 1970, during which he had already been diagnosed with coronary disease and had been hospitalized twice in 1967 and 1968. While employed by White Ways...
Case Digest (G.R. No. L-42893)
Facts:
Employment History and Illness
- Leopoldo Ayuso was employed by White Ways, Inc. as a laborer from 1970 until August 31, 1972, earning a daily wage of P9.00.
- His duties included cleaning toilets, medicine containers, and making repairs in comfort rooms.
- Before working for White Ways, Inc., Ayuso was employed by "Better Buildings," a sister company, from 1965 to 1970.
- During his employment with "Better Buildings," Ayuso was already suffering from a coronary disease and was hospitalized in 1967 and 1968.
Medical Condition and Diagnosis
- On November 12, 1972, while employed by White Ways, Inc., Ayuso was hospitalized at the Philippine General Hospital.
- He was diagnosed with "cor-pulmonable, secondary to primary lung disease with minimal PTB" and had an enlarged heart.
- Doctors Mediadora Claudio and Bravo confirmed that his lung ailment was aggravated by his work and certified that he was unfit for strenuous labor.
- The Physician's Report of Sickness or Injury indicated that Ayuso suffered from total disability.
Claim and Death
- Ayuso filed a claim for compensation benefits on May 16, 1973, but died on August 15, 1975, before the resolution of his claim.
- His wife, Apolonia Bautista, was substituted as the petitioner in the case.
Respondent’s Defense
- The Workmen's Compensation Commission denied Ayuso’s claim, arguing that he failed to prove his illness was contracted during his employment with White Ways, Inc.
- The Commission also contended that Ayuso’s separation from service was due to the closure of the business, not his illness.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Presumption of Compensability
- Under the Workmen's Compensation Act, once an illness supervenes during employment, there is a rebuttable presumption that the illness arose out of or was aggravated by the employment. The burden shifts to the employer to disprove this presumption.
Aggravation of Illness
- The nature of Ayuso’s work (cleaning toilets and performing strenuous tasks) aggravated his pre-existing lung condition, as confirmed by medical reports.
Employer’s Liability Despite Business Closure
- The closure of the business does not negate the employer’s obligation to provide compensation benefits for illnesses contracted or aggravated during employment.
Total Disability
- The Physician's Report of Sickness or Injury established that Ayuso was totally disabled and unfit for strenuous work, entitling him to full compensation under Section 14 of the Workmen's Compensation Act.