Title
Capacio vs. Republic
Case
G.R. No. L-45484
Decision Date
Apr 3, 1988
The court orders the Republic of the Philippines to provide compensation and medical benefits to a public school teacher for illnesses linked to his 33 years of hazardous service.
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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

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