Case Summary (G.R. No. L-43663)
Claim Initiation and Procedural Background
On September 12, 1973, the petitioner filed a notice and a claim for death compensation with the Workmen’s Compensation Commission's Sub-Regional Office No. VII in Bacolod City. The office subsequently sent a copy of this notice to the employer but reported that it was unclaimed. Later, on March 8, 1974, the employer opposed the claim, asserting that the cause of death was neither service-incurred nor service-aggravated. A hearing was held on July 16, 1974, but neither party appeared, leading to a dismissal of the claim by the labor referee for lack of merit. The petitioner’s motion for reconsideration was also denied, prompting her to escalate the matter to the Workmen’s Compensation Commission.
Ruling by the Workmen's Compensation Commission
The Commission affirmed the labor referee's dismissal, stating that while it was established that Eduardo Tortal died from hypertension, the claimant failed to demonstrate a substantial connection between the deceased’s illness and his employment. They indicated that the claimant did not meet the burden of proof necessary to affirm the compensability of the claim, as required under existing jurisprudential standards.
Legal Framework Governing the Claim
Since Eduardo Tortal died prior to the enactment of the 1987 Philippine Constitution, the applicable law governing the compensation claim is the former Workmen's Compensation Act (Act 3428, as amended). According to this law, there exists a disputable presumption of compensability regarding illnesses arising in the course of employment.
Burden of Proof in Workmen's Compensation Claims
It is well-established that if an employee's illness arises during the course of their employment, there is a presumption that the illness is work-related, effectively placing the burden on the employer to prove that the illness was not compensable. The cited precedential cases, including Salanguit v. Workmen's Compensation and Enrique, Sr. v. Republic, provide clarity that once it is shown an illness occurred during employment, the employer must substantiate claims that the illness did not arise from the work environment or was not aggravated by it.
Evaluation of Evidence and Non-Controversion
The Court noted that the employer failed to provide evidence to counter the presumption of compensability regarding Eduardo Tortal's illness. The claim of a drinking spree prior to his death does not dismiss the potential link between his work-related activities and the hypertension that led to his demise. Furthermore, the employer's delayed submission of a controversion—a critical procedural step—constituted
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Case Overview
- The case concerns a petition for review filed by Norena Tortal challenging the decision of the Workmen's Compensation Commission (WCC).
- The WCC affirmed the dismissal of Tortal's claim for death compensation following the death of her son, Eduardo Tortal, a farm laborer.
- Eduardo Tortal worked for Hacienda Celina in E.B. Magalona, Negros Occidental, from 1972 until his death on August 2, 1973, with a daily wage of P8.00.
Factual Background
- Eduardo Tortal passed away due to "hypertension cerebral," as indicated in his death certificate.
- On September 12, 1973, Norena Tortal filed a notice and claim for death compensation with the WCC's Sub-Regional Office in Bacolod City.
- The sub-regional office sent a copy of the notice to the employer, Rodolfo Gamboa, which was returned as "unclaimed."
- The employer submitted a report on March 8, 1974, disputing the claim, arguing that the cause of death was neither service incurred nor service aggravated.
Procedural History
- A hearing was scheduled on July 16, 1974, but both parties failed to appear.
- After submitting memoranda, the labor referee dismissed the claim for lack of merit.
- The petitioner's motion for reconsideration was denied, leading to an elevation of th