Title
Legason vs. Workmen's Compensation Commission
Case
G.R. No. L-43089
Decision Date
Jan 31, 1977
Teacher’s retirement due to work-related ailments; Supreme Court reinstated disability benefits, ruling her conditions were employment-aggravated, and employer’s failure to contest claim waived its defense.
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Case Digest (G.R. No. L-43089)

Facts:

    Employment Background and Service Record

    • The petitioner, Cirila Legason, was employed as a classroom teacher by the Republic of the Philippines through the Bureau of Public Schools.
    • She began her service on June 11, 1923, and worked for over 40 years.

    Occurrence of Illness and Retirement

    • During her employment, petitioner developed significant health issues including hypertension, hypertensive heart disease, and tuberculosis of the lungs with hemoptysis.
    • Due to her ailments, she was compelled to retire on August 31, 1966 under Republic Act No. 660 at the age of 63, a process which required her to meet the conditions for optional retirement.

    Filing and Initial Adjudication of the Claim

    • In September 1972, petitioner filed a formal notice of injury and a claim for compensation.
    • Although the respondent (Republic of the Philippines through the Bureau of Public Schools) tentatively controverted the claim, it ultimately failed to present evidence countering petitioner’s allegations during the hearing before the Acting Labor Referee.

    Decision of the Acting Labor Referee

    • On December 2, 1974, the Acting Labor Referee rendered a decision in favor of petitioner.
    • The decision ordered the respondent to pay a lump sum of P6,000 as disability benefit, along with additional payments covering benefits under Section 13 of Act No. 3428, attorney’s fees, and an administrative fee.

    Reversal by the Workmen’s Compensation Commission

    • Upon review of the case records, the respondent Commission reversed the decision of the Acting Labor Referee and dismissed the claim.
    • The Commission ruled that petitioner was not disabled for labor prior to retirement on the grounds that she only suffered from hypertension and that her retirement was solely due to age and length of service.

    Evidence on Record Contradicting the Dismissal

    • The Report of the Local Claims Committee for Compensation, composed of the School Physician, District Supervisor, and School Principal, provided detailed testimony:
    • It confirmed petitioner’s long service and noted that she retired at age 63 with a final salary of P3,223.56.
    • It documented that petitioner began experiencing hypertension in 1954 and received medical treatment in various institutions, including treatment by Dra. Simeona Virtucio in 1964, which identified hypertensive heart disease.
    • It elucidated that the routine teaching activities, which involved direct supervision of school children and significant emotional strain, contributed to her ailments.
    • It further detailed that petitioner’s daily physical exertion, such as hiking from her residence to her school, exposed her to adverse weather and aggravated her condition.
    • The approved application for optional retirement under Memorandum Circular No. 133 further corroborated that petitioner was physically incapacitated to render further service.

    Legal and Evidentiary Considerations

    • The evidence clearly established that petitioner’s illnesses arose during the course of her employment and were aggravated by the nature of her work.
    • The respondent’s failure to present any contrary evidence during the hearing significantly undermined its tentative controversion of petitioner’s claim.

Issue:

  • Whether the petitioner was physically disabled from labor at the time of her retirement due to work-related illnesses.
  • Whether the respondent’s failure to present evidence during the hearing effectively amounted to an admission of compensability of the claim.
  • Whether the approval of petitioner’s optional retirement at the age of 63 under Republic Act No. 660, which required proof of physical incapacity, conclusively demonstrated her disability.
  • Whether the evidence on record, particularly the medical and testimonial reports, sufficiently established that petitioner’s ailments were contracted or aggravated during the course of her employment, thereby entitling her to compensation under the Workmen’s Compensation Act.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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