Clemente vs. WCC and Rattan Art and Decorations Inc., G.R. No. L-42087, April 8,
1988
Facts:
Ricardo Clemente, a machine set-up man at Rattan
Art and Decorations Inc, died of acute cardiorespiratory
failure, with manifest pulmonary infarct, cardiac dilatation and marked
visceral congestion. The heirs’ claim for death compensation benefits under WCA
was granted. On appeal, the Commission ruled in favor of private respondent and
held that the deceased died from “bangungot” which is non-compensable, there
being no proof of fundamental preliminary link between the cause of death and the
decedent’s work.
Issue:
Whether or not there exist a
causal connection between the cause of death and the nature of work of the
deceased.
Ruling:
The Court held that the deceased died of
“heart failure”,not of “bangungot”. And that there exist the probability that his work, as a set-up man, caused or
aggravated his illness that led to his death. The death was, therefore,
compensable.
Under the WCA, there is the
presumption that the illness which supervened at the time of his employment,
either arose out of or was at least aggravated by, such employment. The burden
of disproving such presumption was on the private respondent. Even granting
that deceased did die of ‘bangungot’, such phenomena is without legal or
medical basis. Where the causes of an ailment are unknown and undetermined even
by medical science, the requirement of proof of causal link between the ailment
and the working conditions should be liberalized.
