Case Digest (G.R. No. L-43640)
Facts:
- Petitioner: Anna Laurio, a teacher with the Bureau of Public Schools from October 1, 1959, to August 31, 1970, and Principal I and II from September 1, 1970, to June 26, 1974.
- Transfer: Moved to the Commission on Elections as Election Registrar of Camarines Sur on June 27, 1974.
- Illnesses: Developed multiple illnesses (sinusitis, goiter, chronic bronchitis) during her tenure with the Bureau of Public Schools.
- Sick Leave: Took sick leave from October 1, 1973, to March 15, 1974, due to these illnesses.
- Claim: Asserted that her illnesses were caused or aggravated by work-related exposure to chalk dust and late-night school activities.
- Initial Dismissal: Claim for compensation dismissed by the Acting Referee on March 12, 1975, due to lack of causal relation to her work.
- Reconsideration Denied: Motion for reconsideration denied on December 15, 1975.
- Appeal: Case elevated to the Workmen's Compensation Commission, which affirmed the dismissal on February 6, 1976, stating her illnesses were not work-related and occurred while on sick leave.
- Supreme Court: Laurio petitioned for a review, treated as a special civil action by the Supreme Court.
Issue:
- (Unlock)
Ruling:
- Causal Relation Affirmed: Yes, Laurio's illnesses were causally related to her employment, making them compensable.
- Presumption Not Rebutted: Yes, the respondent employer failed to rebut the presumption of compensability for Laurio's illnesses.
- ...(Unlock)
Ratio:
- Presumption of Compensability: The Supreme Court found that Laurio's illnesses occurred during her employment, invoking a rebuttable presumption that these illnesses arose out of or were aggravated by her work.
- Health at Employment Start: Laurio was in good health when she began her employment and later developed sinusitis, goiter, and chronic bronchitis.
- Burden of Proof: The burden of proof shifted to the employer to provide substantial evidence to the contrary, which the employer failed to do.
- Conclusive Presumption: The presumption of compensability became conclusive due to the lack of evidence from the employer.
- Chronic Bronchitis: Laurio's chronic bronchitis, which occurred while on sick leave, was traceable to her other illnesses, making it compensable.
- Sick Leave as Employment: The Court emphasized that employe...continue reading
Case Digest (G.R. No. L-43640)
Facts:
The case involves petitioner Anna Laurio, a teacher who served with the Bureau of Public Schools from October 1, 1959, to August 31, 1970, as a classroom teacher, and from September 1, 1970, to June 26, 1974, as Principal I and II. Laurio subsequently transferred to the Commission on Elections as Election Registrar of Camarines Sur on June 27, 1974. During her tenure with the Bureau of Public Schools, Laurio developed multiple illnesses, including sinusitis, goiter, and chronic bronchitis, which led to her taking a sick leave from October 1, 1973, to March 15, 1974. Laurio claimed that her illnesses were caused or aggravated by her work, which involved exposure to chalk dust and late-night activities related to school events. Her claim for compensation was initially dismissed by the Acting Referee on March 12, 1975, on the grounds that her illnesses had no causal relation to her work. Laurio's motion for reconsideration was denied on December 15, 1975, and the case was elevated to the Workmen's Compensation Commission, which affirmed the dismissal on February 6, 1976. The Commission argued that her illnesses were not work-related and occurred while she was on sick leave. Laurio then petitioned for a review, which was treated as a special civil action by the Supr...