Case Summary (G.R. No. L-40658)

Background of the Case

• The petitioner, Crisostomo Aranzanso, was employed by Gami Machineries, Inc. as a carpenter since 1968.
• On September 5, 1971, while on vacation, he suffered a stroke.
• He was treated at the Galauran Memorial Clinic and later at the National Orthopedic Hospital.
• The Compensation Rating Medical Officer determined that he was totally disabled from September 16, 1971, to February 20, 1973.
• Petitioner filed a claim for disability benefits under the Workmen's Compensation Act, which was initially granted by the Acting Referee.

Initial Award and Subsequent Reversal

• The Acting Referee awarded the petitioner temporary and permanent disability benefits, along with reimbursement for medical expenses.
• The respondent company contested the claim, arguing that the stroke occurred while the petitioner was on vacation and was not work-related.
• The Workmen's Compensation Commission reviewed the case and reversed the Acting Referee's decision, dismissing the claim on the grounds that the illness was not compensable since it occurred during a leave of absence.

Legal Principles on Employment and Vacation

• The Supreme Court emphasized that vacation days are considered part of the employment period.
• If an employee suffers an injury or illness during vacation, it is deemed to have arisen out of employment and is therefore compensable.
• The court noted that public policy supports the right of employees to take leave for health and well-being.

Presumption of Work-Related Illness

• The court reiterated the doctrine that an illness is presumed to have arisen out of employment if it occurs during the employment period.
• The burden of proof lies with the employer to demonstrate that the illness did not arise from employment.
• The employee is not required to prove causation; rather, it is sufficient to show that the illness is probable to be work-related.

Evaluation of Evidence and Conclusion

• The records did not provide substantial evidence that the petitioner’s illness was caused by factors unrelated to his employment.
• Even if other factors contributed to the illness, this does not negate the compensability of the claim.
• The court concl...continue reading

Case Syllabus (G.R. No. L-40658)

Case Overview

• The case is a petition for review regarding a decision made by the Workmen's Compensation Commission (WCC) concerning Crisostomo Aranzanso's claim for compensation benefits.
• The case number is G.R. No. L-40658, and the decision was rendered on June 30, 1976, by the First Division of the Supreme Court of the Philippines.

Parties Involved

• Petitioner: Crisostomo Aranzanso
• Respondents: Honorable Associate Commissioner Eugenio I. Sagnit, Jr., in his capacity as Associate Commissioner of the Workmen's Compensation Commission, and Gami Machineries, Inc.

Factual Background

• Crisostomo Aranzanso began his employment with Gami Machineries, Inc. in 1968, working as a carpenter for eight hours a day, six days a week, often including Sundays.
• On September 5, 1971, while on vacation, Aranzanso suffered a stroke, necessitating treatment at the Galauran Memorial Clinic & Laboratory and the National Orthopedic Hospital.
• His total hospitalization costs amounted to P871.25, and he was found to be totally disabled from September 16, 1971, to February 20, 1973, with a 60% permanent partial disability rating.

Initial Claim and Decision

• Aranzanso filed a claim for disability benefits under the Workmen's Compensation Act, which was initially awarded by the Acting Referee of Regional Office No. 4 in Manila.
• The award included temporary total disability compensation, perma...continue reading