**Facts:**
1. Santiago Fabrigar worked as a janitor-messenger for Iloilo Chinese Commercial School from 1947 until March 12, 1956.
2. His duties included sweeping, scrubbing floors, cleaning classrooms, and other janitorial chores.
3. On March 11, 1956, Fabrigar exerted himself heavily, moving desks and chairs and setting up for a graduation ceremony, despite feeling shortness of breath.
4. By March 13, 1956, he spat blood and ceased working; from April 29 to May 15, 1956, he was treated for advanced pulmonary tuberculosis and heart disease by Dr. Quirico Villareal.
5. Santiago Fabrigar died on June 28, 1956.
6. Leonora Fabrigar (common-law wife) and their children filed for compensation with the Workmen’s Compensation Commission (WCC), claiming that Fabrigar’s pulmonary tuberculosis was contracted due to his employment.
7. The WCC Hearing Officer dismissed the claim, stating insufficient evidence linking the deceased’s employment to his illness and death.
8. Leonora Fabrigar and her children appealed to the WCC, which reversed the Hearing Officer’s decision, granting them death benefits and finding that Fabrigar’s employment aggravated his condition, leading to his death.
9. The Iloilo Chinese Commercial School filed a petition for certiorari with the Supreme Court, alleging errors in the WCC’s findings and proceedings.
**Issues:**
1. Whether the Workmen’s Compensation Commission erred in disregarding the death certificate stating the cause of death as “beriberi adult.”
2. Whether the WCC erred in finding that Santiago Fabrigar’s death was due to tuberculosis contracted through employment.
3. Whether Santiago Fabrigar was employed by Iloilo Chinese Commercial School.
4. Whether Iloilo Chinese Commercial School was exempt from the scope of the Workmen’s Compensation Law.
**Court’s Decision:**
1. **Cause of Death:** The Court upheld the WCC’s decision to give more credence to Dr. Villareal’s diagnosis over the death certificate stating “beriberi adult.” The Commission noted that the Sanitary Inspector had not examined Fabrigar before or after his death, leading the court to validate the Commission’s findings that pulmonary tuberculosis was the cause of death.
2. **Contracted Disease in Employment:** The Supreme Court agreed with the WCC that the strenuous activities performed by Fabrigar within his employment aggravated his existing illness, leading to his death. The correlation between his last working day when he spat blood and his death a few months later supported this finding.
3. **Employment Relationship:** The Court supported the WCC’s finding that Fabrigar was, in fact, employed by the school. The evidence indicated that the school’s overseer controlled and supervised Fabrigar’s work, fulfilling the essential test of an employer-employee relationship.
4. **Exemption from Workmen’s Compensation Law:** This issue was dismissed as it had not been properly raised and resolved in the lower proceedings and the motion for reconsideration lacked records showing it was initially argued.
**Doctrine:**
1. **Substantial Evidence Rule:** Employment relations cases before the WCC are governed by substantial evidence rather than preponderance of evidence, as established in Ang Tibay vs. CIR and Phil. Newspaper Guild vs. Evening News.
2. **Employer-Employee Relationship:** The power to control an employee’s conduct constitutes the most crucial test in determining an employer-employee relationship.
**Class Notes:**
– **Substantial Evidence:** In labor cases, substantial evidence—more than a mere scintilla—suffices for decisions, differing from the preponderance of evidence required in civil cases.
– **Employer-Employee Relationship:** Control Test is vital; it assesses who directs how work duties are performed.
– **Pulmonary Tuberculosis and Work-Related Injury:** Proving that work conditions aggravated a pre-existing illness can ground a work-related compensation claim.
**Historical Background:**
The case reflects the mid-20th-century expansion of worker’s compensation laws in the Philippines, particularly as they began covering a broader scope of employment-related injuries and diseases. The decision underscores the tendency of the judicial system to uphold the protections afforded to workers, reflecting the period’s legislative intent to provide robust safeguards against occupational hazards.
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