Case Summary (G.R. No. L-42893)

Case Overview

• Petitioner: Leopoldo Ayuso (now deceased)
• Respondents: Workmen’s Compensation Commission and White Ways, Inc.
• Decision Date: September 30, 1976
• Legal Context: Petition for review of a decision denying compensation benefits under the Workmen's Compensation Act.

Employment and Medical History

• Employment Duration: Ayuso worked for White Ways, Inc. as a laborer from 1970 to August 31, 1972, earning P9.00 daily.
• Prior Employment: He worked from 1965 to 1970 for "Better Buildings," a sister company, and was hospitalized for lung ailments during this period.
• Medical Conditions: Diagnosed with coronary disease and lung ailments, including cor-pulmonable disease and an enlarged heart, with hospitalizations in 1967, 1968, and November 1972.

Claim for Compensation

• Claim Filing: Filed on May 16, 1973, with the Acting Referee of the Regional Office No. IV, Department of Labor.
• Death of Petitioner: Ayuso passed away on August 15, 1975, before the claim was resolved; his wife, Apolonia Bautista, substituted him in the case.
• Total Disability: Medical reports indicated total disability, stating Ayuso was unfit for any strenuous work.

Denial of Compensation

• Commission's Ruling: The Workmen's Compensation Commission denied the claim on the grounds of insufficient evidence linking Ayuso’s illness to his employment and failing to demonstrate that his illness incapacitated him before his separation from service.

Legal Findings by the Supreme Court

• Presumption of Causation: Illnesses that supervene in the course of employment come with a rebuttable presumption that they arose from employment unless substantial evidence to the contrary is presented.
• Employer's Liability: The employer (White Ways, Inc.) had the obligation to manage the risks associated with employing someone with known health issues.
• Burden of Proof: The burden shifted to the employer to disprove the link between the illness and employment.

Compensation Order

• Entitlement: The Supreme Court reversed the Commission’s decision, ordering White Ways, Inc. to pay P6,000.00 in compensation for permanent total disability, alongside attorney's fees of 10% of the payable amount.
• Closing of Business: The cessation of business operations by the employer does not absolve them from liability for compensation benefits owed to employees who became ill during employment.

Key Legal Provisions

• Workmen's Compensation Act:
  • Section 14: Outlines compensation entitlements for total disability.
  • Section 44: Establishes presumptions in favor of the claimants regarding work-related injuries.

Key Takeaways

• The Supreme Court emphasized the employer's responsibility to accommodate employees with pre-existing conditions a...continue reading

Case Syllabus (G.R. No. L-42893)

Case Background

• The case involves a petition for the review of a decision from the Workmen's Compensation Commission which denied compensation benefits to Leopoldo Ayuso (deceased).
• Ayuso filed for compensation benefits on May 16, 1973, while employed by White Ways, Inc. as a laborer from 1970 until his separation on August 31, 1972.
• His employment entailed menial tasks such as cleaning toilets and making repairs in comfort rooms, for which he earned a daily wage of P9.00.
• Before joining White Ways, Inc., Ayuso worked for "Better Buildings" (a sister company) from 1965 to 1970, during which he had a history of coronary disease and was hospitalized multiple times.

Medical History

• Ayuso's medical condition included confinement at the Philippine General Hospital for lung ailments in 1967 and 1968, indicating pre-existing health issues.
• On November 12, 1972, while employed at White Ways, he was again hospitalized, diagnosed with conditions including cor-pulmonale secondary to primary lung disease and minimal pulmonary tuberculosis (PTB), along with an enlarged heart.
• Two doctors confirmed that ...continue reading