Case Digest (G.R. No. L-43089)
Facts:
The case involves Cirila Legason (Petitioner) and the Workmen's Compensation Commission and the Republic of the Philippines, specifically the Bureau of Public Schools (Respondents). The events leading to the litigation commenced on June 11, 1923, when Cirila Legason began her employment as a classroom teacher at the Bureau of Public Schools. Over the years, particularly by 1966, she developed several health problems including hypertension, hypertensive heart disease, and tuberculosis with hemoptysis. Due to these ailments, she retired on August 31, 1966, under Republic Act 660 at the age of 63 after serving more than forty years in government service. In September 1972, Legason filed a formal notice of injury and claim for compensation, which the Republic tentatively controverted. During the hearing before the Acting Labor Referee, the Republic failed to present any evidence against Legason’s claim. On December 2, 1974, the Acting Labor Referee ruled in favor of Legason, awa
Case Digest (G.R. No. L-43089)
Facts:
- 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.
Employment Background and Service Record
- 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.
Occurrence of Illness and Retirement
- 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.
Filing and Initial Adjudication of the Claim
- 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.
Decision of the Acting Labor Referee
- 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.
Reversal by the Workmen’s Compensation Commission
- 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.
Evidence on Record Contradicting the Dismissal
- 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.
Legal and Evidentiary Considerations
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)