VICENTE C. GALANG, PETITIONER, VS. WORKMEN’S COMPENSATION COMMISSION AND SAN MIGUEL CORPORATION, RESPONDENTS.

Galang versus Workmen's Compensation Commission and San Miguel Corporation

The Case

This is a petition for review brought by Vicente Galang against the Workmen's Compensation Commission and his former employer, San Miguel Corporation. Galang asks the Supreme Court to set aside the Commission's decision disallowing his claim for disability compensation benefits. The case matters because it is a clean illustration of the legal presumption of compensability under the Workmen's Compensation Act: once a worker shows that his illness supervened during the course of his employment, the burden shifts to the employer to overcome the presumption by substantial evidence. It also shows how the Court reads a worker's own retirement letter, not in isolation, but in the context of his failing health.

Procedural History

Galang filed a notice of sickness and claim for compensation with the Workmen's Compensation Unit of the Department of Labor in Manila. San Miguel Corporation controverted the claim, insisting that his illnesses had no causal relation to his employment. The Hearing Officer rendered a decision in Galang's favor, ordering the employer to pay six thousand pesos in compensation benefits, three hundred pesos as attorney's fees, and sixty-one pesos as administrative cost. The employer's motion for reconsideration was denied. On appeal, the Workmen's Compensation Commission reversed the Hearing Officer and dismissed the claim for lack of merit. Galang then came to the Supreme Court by petition for review, charging the Commission with grave abuse of discretion.

Facts

Vicente Galang worked as a laborer for San Miguel Corporation for twenty-four years, from 1946 until March 8, 1970, at a daily wage of twelve pesos and ninety-five centavos. His work consisted mainly of loading beer boxes onto trucks and onto ships at the pier. The very nature of that work subjected him to severe physical exertion and exposed him to the elements.

In the early part of February 1970, he became ill. His attending physician diagnosed him with hypertrophic rheumatoid arthritis, essential hypertension, articular arthritis, and chronic ulcer, and reported that these illnesses were aggravated by the very nature of his work. Because of his ailments, he applied for retirement under the company's Health, Welfare and Retirement Plan, effective March 8, 1970, and his application was approved. He received retirement benefits of seven thousand forty-nine centavos and, significantly, was also awarded disability benefits by the Social Security System.

On June 14, 1974, he filed his claim for compensation. The employer resisted, arguing that he was not incapacitated when he retired, that his illnesses could have set in after retirement, and that his own retirement letter showed that his desire to stay healthy and live longer, rather than any disability, moved him to retire.

Issues

• Whether or not the Workmen's Compensation Commission gravely abused its discretion in reversing the Hearing Officer and holding that there was no substantial proof to justify a finding of compensability in favor of Galang.
• Whether or not Galang was disabled while employed with San Miguel Corporation, or was suffering from a disabling sickness at the time of his retirement.

Applicable Provisions

Section 2 of the Workmen's Compensation Act 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 sums and to the person hereinafter specified.

This is the very ground for compensation, and it covers an illness aggravated by the nature of the employment, which is exactly what Galang's physician reported.

Section 14 of the same Act provides:

In case the injury or sickness causes temporary total disability for labor, the employer shall, during such disability, pay to the injured employee a weekly compensation equivalent to sixty per centum of his average weekly wage but not less than fourteen pesos per week, except in the case provided for in the next following paragraph.

This fixes the measure of the disability compensation to which a permanently disabled worker is entitled, and it is the basis of the award reinstated by the Court.

Ruling

On the first issue, the Court ruled in favor of Galang. It held that the fact cannot be disputed that his illnesses set in during the course of his employment, since his physician reported that they were aggravated by the nature of his work. From that fact flows a well settled doctrine: once it is shown that the illness supervened during employment, there is a legal presumption that the illness arose out of, or was at least aggravated in, the course of that employment. The burden then shifts to the employer to overthrow the presumption by substantial evidence. The claimant is relieved from proving causation. Here, the employer adduced no evidence to show otherwise; it merely asserted that Galang was not incapacitated at retirement and that his illnesses could have come later.

On the second issue, the Court also ruled for Galang. It scrutinized his retirement letter and found that the compelling reason for his early retirement was his declining state of health. In that letter he wrote that he was prompted to retire early because of a feeling that his strength was gradually sagging due to his work, and that his desire to stay healthy and live longer overwhelmed his wish to complete twenty-five years of service. His affidavit confirmed that his illness arose out of and in the course of his employment, was aggravated by lifting heavy loads of beer boxes for over twenty years, and worsened until he could no longer perform his work as a laborer. The Court noted that it was in fact due to his disability that he was awarded disability benefits by the Social Security System. Having been forced to retire because of his disability to continue working, he was entitled to disability compensation benefits for persons suffering from permanent disability.

Doctrine

First, once it is shown that the illness supervened during employment, there is a legal presumption that the illness arose out of, or was at least aggravated in, the course of the employment. Second, that presumption shifts the burden to the employer to overthrow it by substantial evidence, and the claimant is relieved from proving causation. Third, a worker's retirement letter must be read in context; a statement of a desire to stay healthy and live longer may itself confirm that declining health, not mere preference, compelled the retirement. These rules tie directly to Section 2 of the Workmen's Compensation Act, which makes the employer liable for an illness aggravated by or the result of the nature of the employment.

Disposition

The Supreme Court reversed the decision of the Workmen's Compensation Commission and reinstated the award made by the Labor Hearing Officer, with no pronouncement as to costs. Galang won.

Remember This

Memorize the line: once the illness supervened during employment, the legal presumption of compensability arises and the burden shifts to the employer to overthrow it by substantial evidence. Examiners use this case to test the presumption of compensability and the reading of retirement letters as evidence of disabling illness.