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...

Facts:

Background of the Case

• Leopoldo Ayuso, the petitioner (later deceased), filed a claim for compensation benefits under the Workmen’s Compensation Act.
• The claim was filed on May 16, 1973, with the Acting Referee of the Regional Office No. IV, Department of Labor in Manila.
• While awaiting the resolution of his claim, Ayuso died on August 15, 1975.
• In accordance with the Rules of Court, his wife, Apolonia Bautista, was substituted for him in the petition.

Employment History and Prior Medical Condition

• Ayuso was employed by private respondent White Ways, Inc. from 1970 until August 31, 1972 as a laborer receiving a salary of P9.00 per day.
• His work involved menial tasks such as cleaning toilets, repairing comfort rooms, and handling medicine containers.
• Prior to his employment with White Ways, he worked for “Better Buildings” (a sister company) from 1965 to 1970.
• During his tenure with Better Buildings, Ayuso was already suffering from coronary disease and was hospitalized twice—in 1967 and 1968—for lung-related ailments.

Medical Developments During Employment with White Ways, Inc.

• While employed by White Ways, on November 12, 1972, Ayuso was again confined in the Philippine General Hospital, where his illness was diagnosed as “cor-pulmonale, secondary to primary lung disease with minimal PTB,” accompanied by an enlarged heart.
• Two attending physicians—Dr. Mediadora Claudio and Dr. Bravo—both opined that his lung ailment was aggravated by his work, certifying that he was unfit for any strenuous duties.
• The Physician’s Report of Sickness or Injury indicated that Ayuso was suffering from total disability.

Proceedings Before the Workmen’s Compensation Commission

• The Workmen’s Compensation Commission denied Ayuso’s claim on several grounds:
• It ruled that Ayuso failed to prove that he contracted his illness while in the employment of White Ways, Inc.
• It stated that even if the illness occurred during employment, there was insufficient evidence that it incapacitated him for labor prior to his separation.
• It noted that the separation from service resulted from the closing of the business or related administrative issues (such as the expiration of the business license), not from his illness.
• The Commission’s decision was later challenged in a petition for review by Ayuso’s legal representatives.

Employer’s Knowledge and Assumption of Risk

• The records revealed that prior hospital confinements (in 1967 and 1968) should have alerted White Ways, Inc. to Ayuso’s physical limitations.
• By employing him despite these warnings, the employer assumed the risk of further aggravation of his condition during his continued employment.

Issue:

Whether the illness for which Ayuso claimed compensation was contracted or aggravated during the course of his employment with White Ways, Inc.

• Determination if the injury or disease qualified as work-related under the Workmen’s Compensation Act.
• Examination of the causal link between the nature of his employment and the worsening of his existing condition.

Whether the evidence sufficiently established that Ayuso’s disability was “total” and prevented him from performing his job duties.

• Scrutiny of the medical reports and physician certifications concerning his physical incapacity.
• Assessment of claims regarding his inability to perform strenuous tasks inherent in his work assignments.

Whether the employer’s justifications regarding Ayuso’s separation from employment (business closure or license expiration) negated its liability for compensable injuries incurred during employment.

• Consideration of whether these factors could lawfully diminish the obligation to provide compensation.
• Analysis of the legal implications of an employer’s operational or administrative decisions on workers’ compensation liability.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)