Primary Holding

The Supreme Court held that Arianza’s liver cirrhosis, though not directly caused by his employment, was aggravated by his working conditions, making it compensable under the Workmen’s Compensation Act.

Background

Arianza worked for Central Azucarera de la Carlota, Inc. from 1960, performing various physically demanding tasks, including packing and piling bagasse and working as a water tender in the fire-room. He developed liver cirrhosis, which he claimed was aggravated by his work conditions. His claim was initially dismissed by the Workmen’s Compensation Commission but was later reversed by the Supreme Court.

Facts

• 1. Arianza was employed by Central Azucarera de la Carlota, Inc. in 1960.
• 2. He underwent a pre-employment medical examination and was found fit to work.
• 3. His duties included packing bagasse, piling bagasse, and working as a water tender in the fire-room.
• 4. His work involved strenuous physical effort, exposure to dust, and immersion in hot water.
• 5. In 1965, he noticed a general weakening of his body, and in 1972, he was diagnosed with liver cirrhosis.
• 6. He stopped working and was hospitalized at the company’s expense.

Arguments of the Petitioners

• 1. Arianza argued that his working conditions, including exposure to dust, heat, and cold, aggravated his liver cirrhosis.
• 2. He claimed that his illness supervened during his employment and was compensable under the Workmen’s Compensation Act.

Arguments of the Respondents

• 1. The respondents argued that Arianza’s illness was not directly caused by his employment.
• 2. They claimed that the company physician’s opinion indicated that exposure to heat and cold was not a factor in the development of liver cirrhosis.

Issues

• 1. Whether Arianza’s liver cirrhosis was compensable under the Workmen’s Compensation Act.

Ruling

• 1. The Supreme Court ruled in favor of Arianza, holding that his illness was compensable.
• 2. The Court found that Arianza’s working conditions, including exposure to dust, heat, and cold, aggravated his liver cirrhosis.
• 3. The Court emphasized that the Workmen’s Compensation Act establishes a presumption of causal connection between the illness and employment, which the employer failed to rebut.
• 4. The Court ordered the respondent company to pay Arianza compensation, provide medical supplies, reimburse medical expenses, and pay attorney’s fees and administrative fees.

Doctrines

• 1. Presumption of Causal Connection: Under the Workmen’s Compensation Act, there is a presumption that an illness that supervenes during employment is either caused or aggravated by the employment.
• 2. Aggravation of Illness: An illness need not be directly caused by employment to be compensable; it is enough that the employment contributed to its aggravation.

Precedents Cited

• 1. Maria Cristina Fertilizer Corporation vs. Workmen’s Compensation Commission, 60 SCRA 228: The Court held that cancer, though not an occupational disease, may be deemed work-connected if working conditions affected the employee’s health.
• 2. Visayan Stevedore and Transportation Company vs. Workmen’s Compensation and Julieta Labiyo, 59 SCRA 89-90: The Court held that when an employee dies on duty, the burden of proof shifts to the employer to show that the death was not work-connected.

Statutory and Constitutional Provisions

• 1. Section 44 of the Workmen’s Compensation Act: Establishes the presumption of causal connection between illness and employment.
• 2. Sections 14 and 18 of the Workmen’s Compensation Act: Govern the payment of compensation and medical expenses.