PETRONILA T. CABALQUINTO, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, (BUREAU OF PUBLIC SCHOOLS), THE WORKMEN’S COMPENSATION COMMISSION (DEFUNCT), SEVERO M. PUCAN, IN HIS CAPAC…

Cabalquinto versus Republic of the Philippines

The Case

This is Petronila T. Cabalquinto versus the Republic of the Philippines, the Bureau of Public Schools, a petition to review a decision of the Workmen's Compensation Commission. The petitioner is a public school teacher and principal who claimed compensation for chronic muscular rheumatism, hypertension, and a weak heart, which she says were contracted in, or at least aggravated by, the nature of her work. The Commission had absolved her employer of any liability, and she asks the Supreme Court to set that ruling aside. The case matters because it shows how the workmen's compensation law treats an illness that supervenes during employment, and how a legal presumption may relieve a claimant of the burden of proving causation.

Procedural History

The petitioner filed her claim for compensation with Regional Office Number Four of the Department of Labor. The respondent did not file a controversion within the reglementary period, but the case was nevertheless heard on the merits. The Acting Referee rendered a decision in favor of the claimant, ordering the respondent to pay disability compensation benefits, attorney's fees, and administrative fees. The respondent appealed to the Workmen's Compensation Commission, which reversed the Acting Referee and absolved the respondent from any liability, on the ground that it was not true that the claimant had to stop working or was ever incapacitated for labor before her retirement. The claimant then brought this petition to review the Commission's decision before the Supreme Court.

Facts

Petronila T. Cabalquinto entered the service of the Bureau of Public Schools on the first of November, 1932, as a classroom teacher of Grades One and Two at the Pasuc Primary School in Badoc, Ilocos Norte. After five years she was designated head teacher of the San Pedro Elementary School in Narvacan, Ilocos Sur, where she supervised eleven teachers, visited classrooms, checked lesson plans, made teaching observations, looked after the upkeep of the school grounds and rooms, and taught English for two periods in Grade Six. On the fifteenth of January, 1970, she was promoted to Principal One with the same place of assignment, performing the same duties with additional work such as directing seminars and acting as consultant during demonstrations. Her tour of duty ran from seven thirty in the morning to twelve noon and from one to five in the afternoon, Monday to Friday, and from eight in the morning to one in the afternoon on Saturdays.

In 1932, when she entered employment, she was in good health and free from any ailment. It was only in 1971, during her employment, that she experienced symptoms of her ailments. Her first treatment was on the fifteenth of August, 1971, when her attending physician, Dr. Alfredo A. Cadena, made a home visit. After a thorough examination he found her to be suffering from hypertension, with a blood pressure then of 190 over 104, chronic muscular rheumatism, and symptoms of dyspnea and easy fatigability. In his report he gave the opinion that her ailments were the result of the nature of her employment, that they were aggravated by the nature of her duties as principal and teacher, and that they resulted in her permanent total disability for labor. He advised her to retire from the service.

When she could no longer stand the pain, she finally stopped working on the nineteenth of September, 1973, and altogether retired on the sixth of October, 1973, as Principal One of the San Pedro Elementary School, with a last annual salary of 5,112 pesos. She incurred expenses for professional fees and medicines of more or less 3,000 pesos, although these were not properly supported by official receipts.

Issues

• Whether or not the ailments of the petitioner, which supervened during her employment, are compensable under the Workmen's Compensation Act.
• Whether or not the respondent overcame the disputable presumption that the claim is compensable.
• Whether or not it is still necessary to pass upon the timeliness of the respondent's appeal to the Workmen's Compensation Commission.

Applicable Provisions

Section 44 of the Workmen's Compensation Act, as cited in the decision, provides:

In the absence of substantial evidence to the contrary, it is presumed that the claim is compensable.

This is the disputable presumption on which the case turns, for it shifts to the employer the burden of showing that the illness is not compensable.

Ruling

On the first issue, the Court held that the claim is compensable. There is no question that the ailments of the petitioner supervened during her employment with the respondent. Hence, there is a disputable presumption that the claim is compensable. The claimant is relieved of the duty to prove causation, because it is then legally presumed that the ailments arose out of the employment.

On the second issue, the Court held that the burden of proof shifted to the employer to establish that the illness is non-compensable, and that the respondent failed to overcome the presumption and the evidence adduced by the petitioner.

On the third issue, the Court held that it is no longer necessary to pass upon the timeliness of the respondent's appeal to the Workmen's Compensation Commission, since the claim succeeds on the merits regardless.

Doctrine

When an illness supervenes during employment, the law raises a disputable presumption that the claim is compensable. The claimant is thereby relieved of the duty to prove causation, and the burden of proof shifts to the employer to establish that the illness is non-compensable. If the employer fails to overcome the presumption with substantial evidence to the contrary, the claim must be granted. This rule is anchored on Section 44 of the Workmen's Compensation Act, which presumes compensability in the absence of substantial evidence to the contrary.

Disposition

The Court set aside the decision of the Workmen's Compensation Commission and ordered the Republic of the Philippines, Bureau of Public Schools, to pay the petitioner 6,000 pesos as disability compensation benefit and 600 pesos as attorney's fees, and to pay the successor of the Workmen's Compensation Commission 61 pesos as administrative fees.

Remember This

The single line worth memorizing is that an illness which supervenes during employment is presumed compensable, and the burden shifts to the employer to prove otherwise. Examiners like to use this case to test the statutory presumption of compensability and the shifting of the burden of proof under the Workmen's Compensation Act.