REMEDIOS MALUPA VDA. DE LAYAG, PETITIONER, VS. REPUBLIC OF THE PHILIPPINES, (BUREAU OF PUBLIC WORKS), RESPONDENT.

Layag versus Republic of the Philippines

The Case

This is Layag versus Republic of the Philippines, a workmen's compensation case decided by the Supreme Court in May 1968. The petitioner, Remedios Malupa Vda. de Layag, is the widow of Alberto Layag, who served for years as chief cook aboard a tugboat of the Bureau of Public Works. She claims death benefits after her husband died of a blood disorder, and the Republic, through the Bureau, resists the claim. The case matters because it fixes the boundary between the statutory presumption that a claim falls within the Workmen's Compensation Act and the requirement that the illness or death be service connected. It also teaches how far an administrative body may inform itself on technical, medical questions without being bound by the technical rules of evidence.

Procedural History

The widow filed a death benefit claim with the Workmen's Compensation Commission, for herself and in behalf of her minor children. The Commission, through its Chairman, turned the claim down, holding that the cause of death was not service connected. The widow appealed. The case reached the Supreme Court on appeal from the decision of the Commission, and the Supreme Court affirmed that decision.

Facts

Alberto Layag worked as chief cook since 1948 aboard the tugboat M/V Chester of the Bureau of Public Works. He passed a pre-employment physical examination that qualified him for the job. As chief cook, assisted by one Vicencio Tomas, he received six pesos and fifty centavos daily and worked from five o'clock in the morning to seven o'clock in the evening. His duties consisted of marketing, cooking food for the crew, setting the table, washing the dishes and utensils, and on certain occasions helping to clean the deck.

His medical history stretched over a decade. Sometime in 1949 he was allegedly hospitalized at the Cagayan de Oro Hospital. In 1955 he contracted influenza and spat blood. On January 23, 1960, he was confined at the San Lazaro Hospital due to fever, body weakness, and brown spots on the skin, diagnosed by his attending physician as hemorrhagic fever. From February 8 to March 2, 1960, he was admitted at the North General Hospital for hypoplastic anemia and ascariasis, and was re-admitted there for the same illness.

He died on March 29, 1960, of thrombocytopenic purpura with cerebral hemorrhage and hypoplastic anemia. His widow then filed the death benefit claim. The Commission found that, apart from his duties as chief cook and the usual chores incidental thereto, the deceased performed no other work, and that the record of his illness did not reveal any causal relation with his job. Its senior medical officer explained that thrombocytopenic purpura is a disorder of the blood marked by a reduction of blood platelets, which may be primary or secondary, and that the cerebral hemorrhage and hypoplastic anemia in this case may be due to defective bleeding and clotting time, which is part of the illness itself.

Issues

• Whether or not the medical study of the Commission's senior medical officer may be considered, although it was not formally offered and received with notice to the claimant.
• Whether or not the presumption under Section 43 of the Workmen's Compensation Act operates in favor of the claimant.
• Whether or not the cause of death of Alberto Layag was service connected.

Applicable Provisions

Section 43 of the Workmen's Compensation Act establishes the presumption the claimant invokes:

In any proceeding for the enforcement of the 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 presumption is the claimant's shield, but it yields once substantial evidence to the contrary appears.

Section 9 of the rules of the Commission governs how it may inform itself:

In the hearing, investigation and determination of any question or controversy and in the exercise of any duties or powers, the Hearing Officer or Commissioner shall act according to justice and equity and the substantial merits of the case, without regard to technicalities or legal forms, and shall not be bound by any technical rule of legal evidence but may inform himself of their merit in such manner as to attain objectives of law.

This provision is the basis for the Court's holding that the medical study was properly considered.

Ruling

On the first issue, the Court held that the Commission did not err in going into the clinical causes of the disease as revealed by the studies of its own medical officer. The cause of death was not disputed. All that the Commission did was to inform itself on the technical questions involved, which it may do under its own rules. The medical study was therefore competent for the Commission's purpose.

On the second issue, the Court held that the presumption in Section 43 does not operate. The illness of which the deceased died shows that it was foreign to the nature of his work, and since this fact is supported by substantial evidence, the presumption is overcome. The Court put the rule thus:

The illness of which the deceased Alberto Layag died shows that it was foreign to the nature of his work, and since this fact is supported by substantial evidence, the presumption in Section 43 of the Workmen's Compensation Act does not operate.

On the third issue, the Court held that the cause of death was not service connected, and affirmed the decision of the Commission.

Doctrine

First, the presumption under Section 43 of the Workmen's Compensation Act is not absolute. It arises only in the absence of substantial evidence to the contrary, and it disappears once the Commission shows by substantial evidence that the illness or death is foreign to the nature of the employee's work.

Second, administrative bodies such as the Workmen's Compensation Commission are not bound by the technical rules of evidence. They may inform themselves on technical and medical questions in such manner as will attain the objectives of the law, and a medical study prepared by their own officer may be considered for that purpose.

Third, the claimant must show that the illness or death is service connected. Where the medical evidence shows that the disease arose from causes internal to the patient and unrelated to the work, the claim must fail.

Disposition

The Supreme Court affirmed the decision of the Workmen's Compensation Commission denying the claim, without cost. The Republic won.

Remember This

The single line to memorize is that the Section 43 presumption does not operate where substantial evidence shows the illness is foreign to the nature of the work. Examiners use this case to test the limits of the workmen's compensation presumption and the relaxed evidentiary rules of administrative bodies.