Facts:

This case involves Emigdio Banez as the petitioner against the Republic of the Philippines, represented by the Bureau of Public Schools, the Workmen's Compensation Commission (now defunct), and the Secretary of Labor. The petition was filed on December 18, 1979, to contest the ruling of the Workmen's Compensation Commission, which had reversed the favorable decision granted by the Acting Referee of Regional Office No. 4, Manila, in R04-WCU Case No. 133139. On July 6, 1972, Banez filed a notice and claim seeking compensation due to his illnesses of pulmonary tuberculosis (PTB) and cardiac insufficiency, which he contended arose from his employment as a public school teacher with the Bureau of Public Schools. The Bureau did not challenge the claim initially, which led to a decision on October 13, 1975, by Acting Referee Celso C. Ladera in favor of Banez, ordering the Bureau to pay him P3,538.80 in compensation, as well as additional attorney's fees and office fees.

The

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Facts:

Background of the Case

• Emigdio Banez, a former classroom teacher of the Bureau of Public Schools, alleged that he suffered from pulmonary tuberculosis (PTB) and cardiac insufficiency due to his employment.
• The claim was based on the physician’s report (Exhibit "C") which supported that his illnesses were caused and/or aggravated by his work.

Filing of the Claim

• On July 6, 1972, while already retired (retired August 5, 1968 at age 63), Banez filed a claim with the Workmen’s Compensation Unit, Regional Office No. 4 in Manila.
• Despite his retirement status, the claim proceeded because the illness was shown to have supervened during his active employment.

Proceedings before the Acting Referee

• Regional Referee Celso C. Ladera rendered a decision on October 13, 1975, in Banez’s favor, ordering payment of:
• P3,538.80 in compensation computed under Section 14 of the Act (60% of his average weekly wage for 104 weeks);
• P176.90 as attorney’s fees pursuant to Section 31 of the Act; and
• P36.00 as an office fee pursuant to Section 55 of the Act.
• The decision provided a clear remedy, recognizing the compensability of the claim.

Appeal to the Workmen’s Compensation Commission

• The respondent, Republic of the Philippines (Bureau of Public Schools), opposed the ruling and filed a motion to set aside the award.
• The Workmen’s Compensation Commission reversed the decision of the Acting Referee on December 31, 1975, dismissing Banez’s claim for lack of merit.

Petition for Certiorari

• Banez, dissatisfied with the reversal, filed a petition for certiorari on December 22, 1976.
• The petition explained the delay in filing due to the administrative difficulties arising from the abolition and record transfer of the Workmen’s Compensation Commission to the Secretary of Labor’s office.
• The petitioner’s counsel detailed multiple attempts to secure records from the new office structure and a subsequent filing of an ex parte petition on December 6, 1976, to obtain necessary documents.

Contentions of the Parties

• Respondents argued that:
• The petition for certiorari was filed out of time since the petitioner received the decision only on March 4, 1976.
• The petitioner’s claim was barred by his retirement prior to filing since he was no longer employed by the Bureau when the claim was made.
• The petitioner contended that:
• Compensation claims for work-related disabilities may be filed within ten (10) years from the onset of the disability.
• The mere fact that he had retired did not preclude his ability to claim compensation for illnesses contracted and aggravated during his employment.

Issue:

Timeliness of the Petition

• Whether the petition for certiorari was filed within the allowable period given the administrative delays in the transfer of records from the Workmen’s Compensation Commission to the Secretary of Labor’s office.
• Whether the petitioner’s claim was bartered by his retirement status, given that his disabilities began during his employment.

Merits of the Compensability of the Claim

• Whether the petitioner’s illnesses (PTB and cardiac insufficiency) were causally linked to his employment with the Bureau of Public Schools, thereby creating a presumptive compensability.
• Whether the respondent adequately refuted the presumption of causation by providing evidence that the illnesses were not related or aggravated by employment.

Legal and Procedural Considerations

• The applicability of the rule allowing claims to be filed within ten (10) years from the start of the disability.
• The shifting of the burden of proof from the claimant to the employer regarding the causation of the illness.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)