Title
Caoili vs. Republic
Case
G.R. No. L-43006
Decision Date
Feb 28, 1979
A teacher, disabled by work-related illnesses, won her claim after the Supreme Court ruled her ailments were presumed compensable, despite retirement and procedural errors.
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Case Digest (G.R. No. L-43006)

Facts:

Employment and Illness:

  • Petitioner Bibiana Caoili was employed as a classroom teacher by the Bureau of Public Schools (now Bureau of Elementary Education).
  • During her employment, she contracted multiple ailments: hypertension, rheumatoid arthritis, chronic bronchial asthma, and diabetes mellitus.
  • These illnesses were first diagnosed as early as 1958, leading to several sick leaves in 1958, 1964, and 1968-1970.
  • Despite medical treatment, her condition worsened, and in 1970, her physician declared her totally and permanently disabled for work.
  • She was forced to retire on December 19, 1970, at the age of 63.

Filing of Claim:

  • On April 15, 1974, Caoili filed a permanent total disability benefit claim under the Workmen's Compensation Act with Regional Office No. 4, Department of Labor.
  • She alleged that her illnesses were service-connected and resulted from her employment.

Respondent's Controversion:

  • On May 21, 1974, the Republic of the Philippines, through the Office of the Solicitor General, controverted the claim, arguing that the illnesses were not caused or aggravated by her employment.

Dismissal by Acting Referee:

  • On October 14, 1975, Acting Referee Eduardo R. Isip dismissed the claim, stating:
    • Petitioner retired in 1970, and there was no employer-employee relationship at the time of filing.
    • The illnesses were not proven to be service-connected or occupational diseases under the Workmen's Compensation Act.

Commission's Decision:

  • On January 14, 1976, the Workmen's Compensation Commission affirmed the dismissal, stating:
    • The claim lacked medical proof to support its credibility.
    • The decision, however, mistakenly referenced another case (Andres D. Cruz v. Republic of the Philippines), leading to a factual error.

Issue:

  1. Whether the illnesses of Bibiana Caoili were service-connected and compensable under the Workmen's Compensation Act.
  2. Whether the employer-employee relationship must exist at the time of filing the claim for compensation.
  3. Whether the Workmen's Compensation Commission committed a grave error by basing its decision on the facts of another case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Dispositive Portion

The Supreme Court ordered the Republic of the Philippines (Bureau of Elementary Education) to:

  1. Pay Bibiana Caoili P6,000.00 as disability compensation.
  2. Reimburse her medical and hospital expenses supported by receipts.
  3. Pay her counsel P600.00 as attorney's fees.
  4. Provide necessary medical, surgical, and hospital services for her ailments.
  5. Pay an administrative fee of P61.00.


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