Facts:

The case involves Tecla Magpantay, who filed a petition for certiorari on behalf of herself and her minor children, Bituin and Carlosa Magpantay, against the Workmen's Compensation Commission and the Republic of the Philippines (Department of Public Highways). The events leading to this case began with the employment of Dionisio Magpantay, the deceased husband of Tecla, who worked as a truck driver for the Bureau of Public Highways from April 4, 1946, until April 15, 1967. Subsequently, he was employed as a driver in the Provincial Engineer's Office of Camarines Norte from January 1, 1968, until November 11, 1971. After that, he worked as a casual laborer in the same office until he was laid off on July 31, 1972, due to a lack of funds. During his employment, Dionisio suffered from chronic cough and underwent treatment for pulmonary tuberculosis (PTB) from August 1969 to November 15, 1973. He died on December 1, 1973, at the age of 66, sixteen months after his separat...

Facts:

Employment History

• Dionisio Magpantay was employed as a truck driver in the Bureau of Public Highways from April 4, 1946, to April 15, 1967.
• On January 1, 1968, he worked as a driver in the Provincial Engineer's Office, Camarines Norte, until November 11, 1971.
• From July 1, 1972, he worked as a casual laborer in the same office until July 31, 1972, when he was laid off due to lack of funds. His daily wage was P8.00.

Health Condition

• From August 1969 to November 15, 1973, Dionisio Magpantay underwent treatment for pulmonary tuberculosis (PTB), caused by excessive driving and exposure to dust, which led to chronic cough.
• He died of pulmonary tuberculosis on December 1, 1973, at the age of 66, sixteen months after his separation from service.

Claim for Compensation

• On February 12, 1974, Tecla Magpantay, Dionisio’s surviving spouse, filed a claim for compensation benefits on behalf of herself and their minor children, Bituin and Carlosa Magpantay, with Regional Office No. V, Department of Labor, Camarines Norte Agency.

Initial Decision

• On October 8, 1975, Regional Office No. V ruled in favor of the claimants, ordering the respondent (Department of Public Highways) to pay:
  1. P6,000.00 as compensation.
  2. P2,032.00 for burial and medical expenses.
  3. P300.00 as attorney’s fees.
  4. P61.00 as administrative fees.

Motion for Reconsideration

• The Office of the Solicitor General filed a motion for reconsideration on October 21, 1975, which was opposed by the petitioner on November 12, 1975.
• On February 12, 1976, the Workmen's Compensation Commission reversed the decision, ruling against the claimant.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Presumption of Compensability: Under Section 44 of the Workmen's Compensation Act, an illness that supervenes during employment is presumed to have arisen out of or been aggravated by the employment. The burden of proof shifts to the employer to disprove this presumption.
2. Aggravation of Illness: The Court found that Dionisio Magpantay’s pulmonary tuberculosis was aggravated by the nature of his work, including exposure to dust and physical exertion, which ultimately led to his death.
3. Two-Year Limitation: The two-year limitation under Section 8 of the Workmen's Compensation Act does not apply in this case. The Court held that the two-year period should be computed from the date of the last aggravation or recurrence of the illness, which was July 31, 1972, when Dionisio was laid off. His death on December 1, 1973, fell within this period.
4. Compatibility with Retirement: The claim for death benefits is compatible with compulsory retirement. The Court emphasized that retirement and death benefits are governed by different laws and should be treated separately.
5. Recurrence of Illness: The Court cited precedent that a recurrence or reactivation of an illness gives rise to a new cause of action, distinct from the original illness.

Conclusion:

The Supreme Court upheld the principle of compensability under the Workmen's Compensation Act, emphasizing the presumption that an illness arising during employment is work-related. The Court rejected the respondent’s arguments and awarded compensation to the heirs of Dionisio Magpantay.