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:

Parties Involved

• Petitioner: Ricardo Bachiller, Sr., a former clerk in the Division of Public Schools, Legazpi City.
• Respondents:
• Republic of the Philippines (Bureau of Public Schools)
• Severo M. Pucan and Dioscora C. Arellano, in their capacities as Chairman and Associate Commissioner, respectively, of the Workmen’s Compensation Commission.

Employment and Service Details

• Petitioner’s service record shows he joined the government service on January 21, 1939.
• He was employed as a Clerk I with duties including procurement of office supplies and materials, assisting with administrative functions, coordination with other offices, and distribution of supplies within the division.

The Claim and Award

• Petitioner sought recovery of disability compensation benefits under the Workmen’s Compensation Act due to ailments incurred during his employment.
• The Acting Referee, Estanislao D. Sarto, issued an award on April 15, 1975, granting:
• P5,237.28 as disability compensation.
• P855.00 as reimbursement for medical expenses.
• The total award amounted to P6,082.28, with a fee of P53.00 charged to the Workmen’s Compensation Commission.

Medical and Disability Facts

• Ailments suffered by the petitioner include rheumatoid arthritis, chest pains, and minimal pulmonary tuberculosis (PTB).
• The condition necessitated intermittent sick leaves from January 5, 1973, leading to a permanent disability as of June 1, 1974.
• Affected capacities:
• Temporary incapacity for labor recorded for at least 625 days (approximately 89-2/7 weeks).
• A 14% permanent disability was determined for his right leg.

Documentary and Medical Evidence

• Evidence submitted by the petitioner consisted of:
• His service record.
• Medical history documents detailing his illnesses contracted during employment.
• Statements of his duties and responsibilities.
• Copies of his leave records and sworn statements of expenses for medicines and professional fees exceeding P1,089.50.
• Certification:
• The Compensation Rating Medical Officer certified the sum of P855.00 as fair and reasonable for medical expenses.
• A report by Municipal Health Officer Dr. Rafael Navera (dated January 13, 1975) linked the petitioner’s chest pains and arthritis to exposure to heat and cold during his official duties.

Procedural History and Controversial Findings

• The initial award by the Acting Referee was later set aside upon appeal by the Office of the Solicitor General on April 24, 1975.
• The Workmen’s Compensation Commission ruled that:
• Rheumatoid arthritis, perceived as a degenerative condition due to aging, was not a compensable illness.
• Consequently, they disallowed the claim for medical expenses.
• The petitioner’s supervisor, Mr. Luis T. Tayo (Division Superintendent of Schools, Legazpi City), endorsed the payment of the disability compensation.

Additional Considerations

• The petitioner had availed himself of optional retirement prior to reaching the compulsory retirement age of 65, indicating physical incapacity.
• The contested facts revolved around whether his employment significantly contributed to the development or aggravation of his illnesses.

Issue:

Compensability of Rheumatoid Arthritis

• Whether rheumatoid arthritis and associated chest pains, which the petitioner suffered while performing his employment duties, are compensable under the Workmen’s Compensation Act.
• Whether the employment conditions materially contributed to the development or aggravation of these conditions.

Validity of the Award Computation

• Whether the computation of disability compensation (P5,237.28) along with the reimbursement of medical expenses (P855.00) as determined by the Acting Referee was appropriate.
• Whether the temporary and permanent disabilities recorded (625 days of temporary inability and 14% permanent disability) justify the award.

Impact of Optional Retirement

• Whether the petitioner’s availing of optional retirement before the age of 65 is a valid indicator of physical incapacity and supports the compensability of his claim.
• Whether the decision to retire early, based on physical incapacity, should influence the award of benefits.

Proper Controversion of the Claim by the Employer

• Whether the respondent employer properly controverted or addressed the evidence of employment contribution to the petitioner’s disabilities.
• Whether the endorsement by the petitioner’s supervisor should have been given greater weight in substantiating the compensability of the claim.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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