Case Summary (G.R. No. L-38421)
Factual Background
Leonora H. Latuno entered government service on July 1, 1946 as a classroom teacher of the Bureau of Public Schools, stationed in Bulan, Sorsogon, and she continuously served in that capacity until February 28, 1959. She later entered employment with the SSS on March 3, 1969 as Clerk I. She was subsequently promoted, eventually reaching the position of supervisor of the Outgoing Mails Unit in the SSS Administrative Department, with a salary of P5,540.00 per annum.
The evidence showed that in 1967 she suffered from arthritis, which worsened in 1969. On June 18, 1969, she wrote to the Administrator of the SSS requesting retirement due to her ailment. On June 1, 1969, she stopped working on account of her condition.
Filing of the Disability Claim and Initial Administrative Ruling
On December 31, 1972, Latuno filed a claim for disability compensation with Regional Office No. 4, Department of Labor, in Manila. The SSS submitted an employer’s report on January 24, 1973 and filed a motion for reinstatement of its right to controvert the claim. The Acting Referee then set the case for hearing on the merits and ruled in favor of Latuno.
The Acting Referee ordered the SSS to pay P6,000.00 as disability compensation and ordered payment of P61.00 as administrative and decision fees.
Appeal to the Workmen’s Compensation Commission
The SSS appealed to the Workmen’s Compensation Commission. The WCC issued a decision dated January 16, 1974 affirming the Acting Referee’s award of P6,000.00 disability compensation pursuant to Sections 14 and 18 of the Workmen’s Compensation Act. The WCC also ordered the SSS to pay P66.00 to the Workmen’s Compensation Fund as administrative cost and fee for the review.
Issues Raised and the Central Factual Controversy
The principal issue raised concerned whether Latuno was afflicted with Osteo-Arthritis in the course of her employment. The Court characterized the matter as a factual issue tied to the administrative findings of both the Acting Referee and the WCC.
Administrative Findings on Causation and Compensability
The Court described the administrative findings as settled: Latuno’s illness supervened during her employment with the SSS. The Acting Referee’s factual findings relied on the evidence that (a) Latuno had been on sick leaves many times due to her illness; (b) she consulted the GSIS General Hospital, where she was diagnosed to be suffering from arthritis; and (c) subsequent examinations by Dr. Arturo Fajardo, Resident Physician of the GSIS General Hospital, confirmed that she had Osteo-Arthritis. The Acting Referee also found that this ailment rendered her physically incapable of performing her duties and led her to seek retirement.
The Acting Referee further found a causal link between employment and the worsening of the condition. Dr. Fajardo’s physician’s report stated that Latuno’s ailment was aggravated by employment, and he testified that physical stress was an aggravating factor. The Acting Referee also took note of the claim that Latuno was exposed to air-conditioned rooms, which allegedly contributed to her arthritic pains. The Acting Referee concluded that there was no evidence that Latuno suffered from Osteo-Arthritis when she entered employment with the SSS and found that she contracted the ailment while in active employment. It stressed that her duties subjected her to constant pressure, involving physical and mental stress, thereby accelerating and aggravating the ailment.
The Acting Referee invoked the compensability presumption for illnesses that arise in the course of employment and treated the illness as legally presumed to have arisen out of employment or at least been aggravated by the nature of her duties. The findings also stated that Latuno was therefore relieved from the burden of proving causation, consistent with authorities cited in the record, including Delgado Brothers, Inc. versus WCC and Agustin versus WCC, and the rule that the claimant was relieved of the burden of proving causation as stated in Justiniano versus WCC.
Ruling of the Court on Review
The Court held that the administrative findings were supported by the evidence on record. It reiterated that it would not review the evidence to determine credibility of witnesses, and it found no showing of grave abuse of discretion in the WCC’s appreciation of evidence. Based on the established finding that Latuno’s illness which made her retire supervened during her employment with the SSS, the Court ruled that there existed a disputable presumption that the claim was compensable.
The Court further held that, once the disputable presumption operated, Latuno was relieved of proving causation, and the burden of proof shifted to the employer to show that the sickness was not compensable. The Court recognized that Latuno’s duties were found to have subjected her to constant pressure and physical and mental stress, which contributed to acceleration and aggravation of her ailment. It held that the petitioner failed to present sufficient evidence to overcome compensability.
The Court also rejected the SSS’s argument that the claim was filed beyond the period prescribed by Section 24 of the Workmen’s Compensation Act. It held that failure to comply with Section 24 was non-jurisdictional and did not bar the proceedings. It added that the Court had previously held that compensation under the Workmen’s Compensation Act was a statutory liability prescribing in ten (10) years, invoking Article 1144(2) of the Civil Code.
Modification on Attorney’s Fees
While the Court affirmed the decision being reviewed, it modified the award by ordering the petitioner to pay Latuno P600.00 as attorney’s fees, in addition to the disability compensation ben
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Case Syllabus (G.R. No. L-38421)
Parties and Procedural Posture
- The petition for review involved Social Security System as petitioner and Workmen’s Compensation Commission and Leonora H. Latuno as respondents.
- The Workmen’s Compensation Commission affirmed the Acting Referee of Regional Office No. 4, Department of Labor, Manila, which ordered petitioner to pay disability compensation and administrative costs and fees.
- The Acting Referee ordered petitioner to pay PHP 6,000.00 as disability compensation and PHP 61.00 as administrative and decision fees.
- The Workmen’s Compensation Commission sustained the award and required petitioner to pay the claimant the PHP 6,000.00 compensation pursuant to Sections 14 and 18 of the Workmen’s Compensation Act.
- The Workmen’s Compensation Commission further required petitioner to pay PHP 66.00 as administrative cost and fee for the review.
- The Supreme Court reviewed only the legal issues raised by petitioner, while respecting the factual findings of the Acting Referee and the Workmen’s Compensation Commission.
Claimant’s Employment and Illness
- Leonora H. Latuno entered government service on July 1, 1946 as a classroom teacher of the Bureau of Public Schools in Bulan, Sorsogon, and she continuously served until February 28, 1959.
- On March 3, 1969, claimant was employed by Social Security System as Clerk I.
- She advanced through successive positions, including supervising clerk, senior clerk, and supervisor of the Outgoing Mails Unit of the Administrative Department, with a salary of PHP 5,540.00 per annum.
- In 1967, claimant suffered from arthritis, and the condition became worse in 1969.
- On June 18, 1969, claimant wrote to the Administrator of the Social Security System requesting retirement due to her ailment.
- On June 1, 1969, claimant stopped working because of her physical condition.
Key Allegations in the Workmen’s Compensation Claim
- Claimant filed a claim for disability compensation with Regional Office No. 4, Department of Labor at Manila on December 31, 1972.
- The central question for compensation was whether claimant was afflicted with Osteo-Arthritis in the course of her employment with the Social Security System.
- Petitioner disputed compensability by raising both factual and procedural arguments, including the timeliness of the claim under Section 24 of the Workmen’s Compensation Act.
- The Acting Referee and the Workmen’s Compensation Commission found that Osteo-Arthritis supervened during claimant’s employment and rendered her physically incapable of performing her duties.
Medical Evidence and Causation Findings
- The Acting Referee found “apparently no dispute” that claimant was afflicted with Osteo-Arthritis during her employment.
- The medical evidence on record showed that claimant was on sick leave on multiple occasions and made consultations with the GSIS General Hospital where she was diagnosed with arthritis.
- Subsequent examinations by Dr. Arturo Fajardo, Resident Physician of the GSIS General Hospital, confirmed the diagnosis of Osteo-Arthritis.
- The medical findings were treated as supporting the conclusion that the ailment physically incapacitated claimant, prompting her retirement application.
- The Acting Referee credited Dr. Arturo Fajardo’s physician’s report stating that the ailment was aggravated by employment.
- The Acting Referee further relied on Dr. Arturo Fajardo’s testimony that physical stress aggravated arthritis.
- The Acting Referee also noted that claimant was exposed to air-conditioned rooms, which allegedly contributed to the pains of her arthritis.
- The Acting Referee concluded that there was no evidence that claimant suffered from Osteo-Arthritis when she entered employment with the Social Security System.
- The Acting Referee held that claimant’s duties subjected her to constant pressure, physical and mental stress, and that such work contributed to the acceleration and aggravation of her ailment.
- The Acting Referee relied on the legal presumption that when the claimant is afflicted with the illness in the course of employment, the illness is presumed to have arisen out of employment or at least to be aggravated by the nature of her duties.
Statutory Framework
- Compensation was awarded under Sections 14 and 18 of the Workmen’s Compensation Act.
- Section 24 of the Workmen’s Compensation Act was invoked by petitioner to argue that the claim was filed beyond the prescribed period.
- The Supreme Court treated compliance with Section 24 as non-jurisdictional, consistent with its settled doctrine.
- The decision invoked Article 1144 (2) of the Civil Code of the Philippines to explain that co