Title
Seven-Up Bottling Company of the Philippines vs. Rimerata
Case
G.R. No. L-24349
Decision Date
Dec 24, 1968
Virgilio Rimerata, a lab helper, developed a peptic ulcer from work conditions, deemed compensable by the Workmen's Compensation Commission, upheld by the Supreme Court.

Case Digest (G.R. No. L-24349)
Expanded Legal Reasoning Model

Facts:

  • Background of Employment and Work Conditions
    • Claimant Virgilio Rimerata was employed as a laboratory helper by Seven-Up Bottling Company of the Philippines from March 17, 1953, until his termination on December 15, 1962.
    • His duties included:
      • Preparing sugar and tasting the syrup for correction in accordance with established standards.
      • Weighing and mixing ingredients such as citric acid, sodium citrate, carbonated water, lemolime, and alcohol using an electrically operated mixing tank.
      • Pouring acoustic soda into the bottle washing machine.
      • Changing the water analyzer in the water tank.
      • Carrying out the manual task of transporting 16–54 sacks of sugar (each weighing 100 lbs.) over a ten-meter distance during an eight-hour workday.
    • He worked eight hours daily, six days a week, with his last wage rate recorded at P5.85 daily.
  • Onset and Development of Illness
    • After three or four years of service, Rimerata began experiencing pain in his abdominal region.
    • On April 6, 1962, while on duty, he suffered from severe stomach pains accompanied by vomiting, prompting immediate treatment by the employer's physician, Dr. Gil Angeles.
    • Dr. Angeles diagnosed his ailment as peptic ulcer and advised his confinement at home.
    • Despite continued medical treatment under Dr. Angeles until June 26, 1962 and subsequently under Drs. Jose C. Almeda, Clodualdo S. Manas, and Dr. Charles S. Harn, Rimerata’s condition showed no significant improvement.
    • Due to his persistent illness, the petitioner terminated Rimerata's employment on December 15, 1962.
  • Proceedings Before the Workmen’s Compensation Commission
    • The Workmen’s Compensation Commission issued an order requiring the petitioner to:
      • Pay the claimant a sum of P3,041.66 as compensation (computed as 60% of P35.10 for 144 3/7 weeks) and a weekly compensation of P21.06 from January 16, 1965 until his disease was declared arrested or cured, not exceeding the P4,000.00 maximum set by law.
      • Provide necessary medical, surgical, and hospital services along with supplies under Section 13 of the applicable Act.
      • Reimburse the claimant P200.00 for medical expenses incurred.
      • Pay fees to the Workmen’s Compensation Fund as stipulated by law.
  • Issues Raised by the Petitioner in the Appeal
    • Petitioner contended that the Commission erred in its findings regarding:
      • Determination of the claimant's disability period (asserting the disability was not proven to last until January 15, 1965).
      • Allocation of the burden of proving the duration of disability between the claimant and petitioner.
      • Causation—specifically, that the claimant’s peptic ulcer did not arise from or relate to his work conditions, including his duty of tasting the syrup mixture.
      • Compensability of the claimant’s condition as it relates to his work with the petitioner.
  • Evidence on Causation and Work-Related Factors
    • Testimonies from key witnesses played a crucial role in establishing the connection between the claimant’s work and his health condition:
      • Ruben Rodriguez, the production department foreman.
      • Crispin Peralta, the petitioner’s Assistant Manager.
    • Medical evidence, including Dr. Charles S. Harn’s certificate (Exhibit B-2), pointed to the likelihood that exposure to certain ingredients in the workplace could have irritated the claimant’s stomach lining, either producing or aggravating the peptic ulcer.

Issues:

  • Determination of Disability Duration
    • Whether the Workmen’s Compensation Commission erred in concluding that Rimerata was disabled for work until January 15, 1965.
    • Whether the burden of proving the exact period of disability lay with the claimant or the petitioner.
  • Causation of the Ailment
    • Whether there was sufficient evidence to establish that the claimant’s peptic ulcer was caused by or was reasonably connected to the exposure from tasting the syrup and handling other ingredients during his employment.
    • Whether the evidence supported the conclusion that the nature and conditions of work significantly aggravated the claimant’s condition.
  • Compensability of the Claimant’s Condition
    • Whether the ailment, regardless of the exact duration or causation debate, qualifies as compensable under the provisions of the applicable workmen’s compensation laws.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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