G.R. No. L-26657 - Visayan Stevedore and Transportation Co. vs. Workmen's Compensation Commission

Eduardo Labiyo was employed as an engineer by Visayan Stevedore & Transportation Company and was part of a three-man crew aboard the tugboat “M/T Dilis.”
His primary duty was to start the engine and ensure its proper functioning while the actual navigation was handled by the tugboat’s patron and a helper (timonel).

From February 10 to 17, 1964, the entire crew was engaged in continuous, around-the-clock work involving towing barges, shifting them to drydock, and other related operations.
On February 17, 1964, during towing operations at about 4:00 a.m., Labiyo, appearing visibly tired from continuous duty, requested permission to sleep.
After receiving permission, he was permitted a brief rest in his bunk, where he later was discovered lifeless around 6:30 a.m.

An autopsy conducted by Dr. Raymundo L. Torres attributed the cause of death to “bangungot,” a term that highlights a condition not clearly explained or scientifically established.
The autopsy report noted no external lesions on the head, neck, thorax, abdomen, or extremities, with the stomach found full yet interpreted as an insignificant finding given the timeline of meals and digestion.

Julieta Labiyo, the widow, filed a claim for compensation benefits, burial expenses, and associated costs with the Department of Labor, Regional Office No. VII, Iloilo City.
Initially, the Workmen’s Compensation Unit dismissed the claim on the ground that the cause of death did not arise out of or was not aggravated by Labiyo’s employment.
The decision was subsequently reversed by the Workmen’s Compensation Commission, which affirmed the compensability of the claim, and motions for reconsideration by the petitioner were denied in an en banc resolution dated August 30, 1966.

The petitioner, Visayan Stevedore & Transportation Company, argued that death by “bangungot” could not be attributed to work-related overexertion or fatigue since the deceased was not engaged in heavy physical or manual labor immediately prior to his death.
The company maintained that the nature of Labiyo’s work afforded him sufficient opportunity to rest, thereby challenging the causal linkage between his duties and his sudden death.

Whether Eduardo Labiyo’s death, attributed medically to “bangungot,” should be considered compensable under the Workmen’s Compensation Act.
Whether the evidence of continuous, 24-hour duty and the fatigue resulting therefrom sufficiently establishes that his death arose out of or was aggravated by his employment, regardless of the disputed medical cause.
The extent to which the autopsy report and the contested explanation of “bangungot” can displace the statutory presumption of work-connected causation under Section 44 of the Act.