Case Digest (G.R. No. L-45484)
Facts:
- Zosimo Capacio, a public school teacher for 33 years, filed a case against the Republic of the Philippines, represented by the Bureau of Public Schools.
- He retired on August 13, 1974, at the age of 60 due to health issues, including peptic ulcer, hypertension, and schistosomiasis, which he claimed began on March 19, 1973.
- After retirement, he underwent a medical check-up by the Workmen's Compensation Commission (WCC) and continued treatment until September 15, 1974.
- Capacio filed a claim for compensation benefits under the Workmen's Compensation Act.
- Initially, a hearing officer awarded him P5,693.57 for sickness compensation and medical expenses on November 24, 1975.
- The Office of the Solicitor General filed a motion for reconsideration, leading the WCC to reverse the award, citing insufficient documentary evidence and suggesting retirement was for benefits, not illness.
Issue:
- (Unlock)
Ruling:
- The Supreme Court reversed the WCC's decision and reinstated the original award made by the hearing officer.
- The Court ruled in favor of Zosimo Capacio, affirming that his illnesses were work-related. ...(Unlock)
Ratio:
- The Supreme Court recognized the presumption of compensability under the Workmen's Compensation Act.
- Once an illness is shown to have occurred during employment, a rebuttable presumption arises that it is work-related, shifting the burden of proof to the employer.
- The Court determined that Capacio's ailments were aggravated by the demanding conditions of his teaching jo...continue reading
Case Digest (G.R. No. L-45484)
Facts:
The case involves Zosimo Capacio, the petitioner, against the Republic of the Philippines, represented by the Bureau of Public Schools, the respondent. The events leading to this case unfolded in Northern Samar, where Capacio served as a public school teacher for 33 years. He began his career as a substitute teacher and eventually became a regular teacher. On August 13, 1974, at the age of 60, he retired due to health issues, specifically peptic ulcer, hypertension, and schistosomiasis, which he claimed began affecting him on March 19, 1973. Following his retirement, he was summoned for a medical check-up by the Workmen's Compensation Commission (WCC) and continued to receive treatment until September 15, 1974. Capacio filed a claim for compensation benefits under the Workmen's Compensation Act, which was initially heard by a hearing officer who awarded him P5,693.57 for sickness compensation and medical expenses on November 24, 1975. However, the Office of the Solicitor General filed a motion for reconsideration, leading the WCC to reverse the award, citing a lack of documentary evidence to support Capacio's claims and suggesting that his retirement was not due to his illnesses but rather to enjoy retirement benefits.