Title
Canete vs. Workmen's Compensation Commission
Case
G.R. No. L-43086
Decision Date
May 8, 1985
A public school teacher’s death from pulmonary tuberculosis was ruled compensable under the Workmen’s Compensation Act, as her illness supervened during employment, and the employer failed to rebut the presumption of compensability.
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Case Digest (G.R. No. L-43086)

Facts:

  1. Employment Details: Felicitacion E. Canete was a public school teacher for four years until her death on May 15, 1967. She was initially assigned to Tubaran Elementary School for two weeks and later transferred to Tambacan Community School.
  2. Medical Condition: On August 8, 1966, Canete was diagnosed with pulmonary tuberculosis. She was hospitalized at Sacred Heart Hospital and later transferred to Cebu TB Pavilion for treatment. She died on May 15, 1967.
  3. Claim for Compensation: On August 3, 1967, petitioners Felipe Z. Canete, Allyn, and Andrew filed a claim for death compensation benefits under the Workmen's Compensation Act. The claim was received by the Workmen's Compensation Unit on August 15, 1967.
  4. Controversion of Claim: The Solicitor General informed the Bureau of Public Schools of the claim and requested necessary documents. On February 16, 1968, the Solicitor General controverted the claim, arguing that the illness was not work-connected.
  5. Referee's Decision: The acting referee declared the claim non-controverted on June 17, 1968. The Solicitor General filed a motion to set aside the order, which was denied. On February 5, 1969, the acting referee granted death compensation benefits, declaring the illness as compensable.
  6. Commission's Decision: On December 4, 1975, the Workmen's Compensation Commission reversed the decision, denying the claim and stating that pulmonary tuberculosis was not compensable per se under the Act.

Issue:

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Ruling:

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Ratio:

  1. Presumption of Compensability: The Court applied the presumption of compensability under Section 44 of the Workmen's Compensation Act, as amended. Since the illness supervened during employment, the burden of proof was shifted to the employer to establish that the illness was not compensable. The employer failed to provide substantial evidence to rebut this presumption.
  2. Nature of Employment: The deceased's employment as a public school teacher exposed her to harsh elements and physical fatigue, which weakened her physical stamina and made her susceptible to diseases. The Court concluded that the nature of her employment caused and aggravated her ailment.
  3. Legal Precedent: The Court cited numerous cases where the presumption of compensability was applied once it was proved that the illness supervened during employment.
  4. Failure to Validly Controvert: The Solicitor General's notice of controversion was defective as it did not specify clear grounds for controversion. Failure to validly controvert a claim results in a constructive admission of the claim's compensability.
  5. Social Legislation Purpose: The Workmen's Compensation Act is a social legislation designed to give relief to the working man. The Court emphasized that strict rules of evidence are not applicable in workmen's compensation cases, and the degree of proof required is merely substantial evidence.


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