Facts:

The case involves Ricardo Bachiller, Sr., a former Clerk I at the Division Office of Public Schools in Legazpi City, who filed for disability compensation under the Workmen's Compensation Act due to ailments he claimed were work-related. Bachiller, aged 64 at the time of the claim, had been suffering from rheumatoid arthritis and chest pains since January 5, 1973, which led to intermittent sick leaves and ultimately a permanent disability that rendered him unable to work as of June 1, 1974. On April 15, 1975, Acting Referee Estanislao D. Sarto of Regional Office No. 6, Department of Labor in Naga City, awarded him a total of P6,082.28, which included compensation and reimbursement for medical expenses. The award was based on evidence including Bachiller's service record, medical history, and a report from the Municipal Health Officer, Dr. Rafael Navera, who attributed his ailments to his work conditions. However, the Workmen's Compensation Commission, upon appeal ...

Facts:

1. Claimant's Background:

   • Ricardo Bachiller, Sr., a 64-year-old Clerk I in the Division Office of Public Schools in Legazpi City, joined government service on January 21, 1939.
   • His duties included procurement of office supplies, assisting the Division Supply Officer, canvassing requisitioned articles, distributing supplies, and serving as a liaison officer.

2. Medical Condition:

   • Bachiller suffered from Rheumatoid Arthritis, chest pains, and minimal Pulmonary Tuberculosis (PTB) starting January 5, 1973.
   • His ailments necessitated frequent sick leaves and permanently disabled him from work as of June 1, 1974, based on medical advice.
   • He incurred medical expenses amounting to over P1,089.50, of which P855.00 was certified as reasonable by the Compensation Rating Medical Officer.

3. Disability and Compensation:

   • The Acting Referee awarded Bachiller P5,237.28 as compensation and P855.00 as reimbursement for medical expenses, totaling P6,082.28.
   • The Workmen's Compensation Commission, however, reversed this award, stating that rheumatoid arthritis is a degenerative condition due to aging and not compensable.

4. Medical Certification:

   • Dr. Rafael Navera, the Municipal Health Officer, certified that Bachiller's ailments were caused by exposure to heat and cold during his duties, such as mailing and distributing supplies.

5. Optional Retirement:

   • Bachiller availed of optional retirement before reaching the compulsory retirement age of 65, which the Court interpreted as evidence of physical incapacity.

6. Endorsement by Supervisor:

   • Bachiller's supervisor, Luis T. Tayo, Division Superintendent of Schools, endorsed the payment of disability compensation.

Issue:

1. Whether Bachiller's ailments (Rheumatoid Arthritis, chest pains, and PTB) are compensable under the Workmen's Compensation Act.
2. Whether the Workmen's Compensation Commission erred in reversing the Acting Referee's award.
3. Whether Bachiller's optional retirement before the compulsory age of 65 is indicative of his physical incapacity.

Ruling:

The Supreme Court set aside the decision of the Workmen's Compensation Commission and reinstated the Acting Referee's award in favor of Ricardo Bachiller, Sr. The Court held that:

1. Bachiller's ailments were compensable under the Workmen's Compensation Act, as they occurred in the course of employment and were aggravated by his duties.
2. The presumption of compensability under Section 44 of the Act applies, and the employer failed to properly controvert the claim.
3. Bachiller's optional retirement before reaching the compulsory age of 65 is evidence of his physical incapacity to render further efficient service.

Ratio:

1. Presumption of Compensability:

   • Under Section 44 of the Workmen's Compensation Act, there is a presumption that a claim is compensable if the illness occurred in the course of employment. The employer bears the burden of disproving this presumption, which was not done in this case.

2. Aggravation by Employment:

   • Even if other factors, such as aging, contributed to the illness, the employment need only be a contributing factor, not the sole cause, for the claim to be compensable.

3. Optional Retirement as Evidence of Incapacity:

   • The Court reiterated that optional retirement before the compulsory age of 65 is a clear indication of physical incapacity, as per Memorandum Circular No. 133 issued by the Office of the President.

4. Endorsement by Supervisor:

   • The endorsement of Bachiller's claim by his supervisor further supports the compensability of his claim.

5. Reinstatement of Award:

   • The Court found no legal basis to deny the award granted by the Acting Referee and directed the Bureau of Public Schools to provide Bachiller with necessary services and supplies for his recovery.