FLORENTINO R. MATTA, PETITIONER, VS. WORKMEN’S COMPENSATION COMMISSION AND DEVELOPMENT BANK OF THE PHILIPPINES, RESPONDENTS.

Matta versus Workmen's Compensation Commission

The Case

This is a petition filed by Florentino R. Matta against the Workmen's Compensation Commission and the Development Bank of the Philippines, seeking the reversal of the Commission's decision denying his claim for compensation. Matta claims that his illness, cataract on both eyes coupled with diabetes mellitus and a heart ailment, was contracted and aggravated in the course of his employment with the bank, and that the law presumes it compensable. The case matters because it is a classic illustration of the presumption of compensability under the Workmen's Compensation Act, the shifting of the burden of proof to the employer, and the fatal effect of a late controversion.

Procedural History

Matta filed a Notice of Injury or Sickness and Claim for Compensation with the Workmen's Compensation Unit. Acting Referee Gerardo D. Rabanes denied the claim in an order dated October 23, 1975, on the ground that his duty as assistant purchasing officer was not in any way related to his illness. Matta appealed to the Workmen's Compensation Commission, which affirmed the denial, ruling that the cataract was the result of the aging process and that the records contained no evidence to support the claim. Matta then brought this petition before the Supreme Court, which reversed the Commission and granted the claim.

Facts

Florentino R. Matta was first employed by the defunct Rehabilitation Finance Corporation, now the Development Bank of the Philippines, on January 1, 1947 as a chief guard. He served as such until May 2, 1960. He then became a collateral clerk, and from August 1, 1960 up to his retirement on October 31, 1972, he was an assistant purchasing officer. Before his appointment as chief guard, he passed the pre-employment medical check-up and was found physically fit and free from any ailment.

On January 18, 1960, while performing his duties as chief guard, a fire broke out at the second floor of the bank's building. While trying to extinguish the fire, Matta's eyes were sprayed by a fire extinguisher with its poisonous caustic soda, and his face was almost burned. He was hospitalized at the instance of the bank. From then on, he experienced blurring of vision and was in regular consultation with eye specialists. On August 19, 1966, again at the instance of the bank, he was admitted at the UST Hospital and operated on for cataract on both eyes. His blurring vision with cataract was coupled with diabetes mellitus and a heart ailment, all contracted while in the employ of the bank.

Upon the advice of his attending physicians, Matta retired on October 3, 1972 at the age of 62 years and 26 days. On March 30, 1975, he filed his claim for compensation, alleging that he was forced to retire on the ground of disability by reason of the illness he contracted while in the service. The bank filed its answer on October 2, 1975, stating that it desired to controvert the claim and that the cataract was not compensable and could not have been caused or aggravated by his work.

Issues

• Whether or not Matta's illness is compensable under the Workmen's Compensation Act, considering the presumption of compensability and the evidence on record.
• Whether or not the bank's failure to file a timely notice of controversion barred it from contesting the claim.

Applicable Provisions

Section 2 of Act 3428, as amended by Republic Act No. 4119, provides:

When an employee suffers personal injury from any accident arising out of and in the course of his employment, or contracts tuberculosis or other illness, directly caused by such employment, or either aggravated by or the result of the nature of such employment, his employer shall pay compensation in the sum and to the person hereinafter specified.

This is the very provision under which Matta filed his claim, and it defines the coverage the Court must apply.

Section 44 of the Workmen's Compensation Act provides:

In any proceeding for the enforcement of a claim for compensation under this Act, it shall be presumed, in the absence of substantial evidence to the contrary, that the claim comes within the provisions of this Act.

This establishes the presumption of compensability that shifts the burden to the employer.

Section 45 of the Workmen's Compensation Act requires the employer to file its notice to controvert the right to compensation on or before the fourteenth day of disability or within ten days after it had knowledge of the illness. The Court applied this period in holding that the bank's controversion, filed only on October 2, 1975, came too late.

Ruling

On the first issue, the Court ruled that the claim is compensable. Section 44 establishes a presumption of compensability, and it becomes the duty of the employer to show that the claim does not come within the coverage. The Court held that once the illness supervened in the course of employment, it is presumed that the illness arose out of the employment or was at least aggravated by it, and the precise medical cause is not legally significant. The bank presented no evidence to substantiate its contention that the illness was not work-connected. The Court also rejected the argument that the cataract was the result of the aging process, holding that advancing age alone will not remove the ailment from the periphery of compensable disabling diseases. In compensation cases, strict rules of evidence are not applicable; a reasonable work-connection is all that is required, and the test is probability, not certainty.

On the second issue, the Court ruled that the bank's failure to file a timely notice of controversion constituted a renunciation of its right to controvert the claim. The bank knew of Matta's confinement at the UST Hospital on August 19, 1966, for it was even instrumental in his admission, yet it registered no controversion within the periods required by Section 45. The absence of controversion is fatal to any defense the employer could interpose.

Doctrine

Under Section 44 of the Workmen's Compensation Act, once an illness supervenes in the course of employment, a rebuttable presumption arises that it arose out of the employment or was at least aggravated by it. The burden shifts to the employer to overthrow the presumption by substantial evidence, and the employee is relieved of the burden of proving causation. The precise medical cause of the illness is not legally significant. Advancing age does not remove an ailment from the coverage of the law. Under Section 45, the employer must controvert the claim within fourteen days from disability or ten days from knowledge of the illness; failure to do so is a renunciation of the right to controvert, and the claim becomes beyond challenge. All doubts in the interpretation of labor laws are resolved in favor of the worker.

Disposition

The Court reversed the decision of the Workmen's Compensation Commission and ordered the Development Bank of the Philippines to pay Matta Six Thousand Pesos as disability compensation benefits, Five Hundred Pesos as reimbursement of medical and hospital expenses, Six Hundred Pesos as attorney's fees, and the costs.

Remember This

The single line worth memorizing is that once the illness supervenes in the course of employment, the presumption of compensability arises, and the employer's failure to timely controvert the claim is fatal to its defense. Examiners like to use this case on the presumption of compensability, the burden of proof in workmen's compensation cases, and the effect of a late controversion under Section 45.