Title
Bayogbog vs. Workmen's Compensation Commission
Case
G.R. No. L-44232
Decision Date
Sep 11, 1980
Paciencio Bayogbog sought compensation for contracting pulmonary tuberculosis during his employment with Marinduque Mining & Industrial Corporation, ultimately winning the case and receiving disability compensation, reimbursement of medical expenses, attorney's fees, and administrative fees. The Workmen's Compensation Commission ruled in favor of the petitioner, finding that the illness was contracted during his employment and that the employer failed to provide evidence to contest the claim.
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Case Digest (G.R. No. L-44232)

Facts:

  • Paciencio Bayogbog, the petitioner, sought compensation for contracting pulmonary tuberculosis during his employment with Marinduque Mining & Industrial Corporation, Surigao Nickel Project.
  • Bayogbog filed a Notice of Injury or Sickness and Claim for Compensation on March 3, 1975, alleging he contracted "pulmonary tuberculosis, moderately advanced infection" while employed by the respondent.
  • The respondent, through its Assistant Vice-President, did not contest the claimant's right to compensation.
  • The Acting Referee and Chief of the Workmen's Compensation Unit, Regional Office No. 9, issued an award on October 8, 1975, granting Bayogbog P4,505.34 as disability compensation.
  • Both parties received copies of the award on November 5, 1975. No motion for reconsideration or petition for review was filed by the respondent.
  • Bayogbog moved for execution, and a writ of execution was issued on February 17, 1976.
  • The respondent filed a motion to set aside the award and writ of execution on March 22, 1976, claiming the award was null and void due to lack of jurisdiction.
  • The Chairman of the Workmen's Compensation Commission reversed the Referee's award on March 29, 1976.
  • Bayogbog was employed as a laborer from September 13, 1968, until his termination on February 1, 1975, due to his illness.
  • Dr. Jose P. Bayana, Jr.'s Physician's Report indicated that Bayogbog's illness supervened on November 18, 1974, and was a result of his employment.
  • The Workmen's Compensation Act was applicable as the illness occurred during his employment.
  • The petitioner presented evidence supporting his claim, while the respondent failed to rebut the presumption or provide contrary evidence.

Issue:

  • (Unlock)

Ruling:

  1. The Supreme Court ruled that Paciencio Bayogbog's pulmonary tuberculosis is compensable.
  2. The Supreme Court set aside the decision of the Workmen's Compensation Com...(Unlock)

Ratio:

  • The Supreme Court found that Bayogbog contracted pulmonary tuberculosis during his employment, invoking a disputable presumption of compensability under the Workmen's Compensation Act.
  • This presumption relieved Bayogbog of the burden to prove causation, shifting the burden to the employer to disprove the claim.
  • T...continue reading

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