Case Digest: Clemente vs. WCC and Rattan Art and Decorations Inc.

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.

Categories: 1988, April 8, Clemente vs. WCC and Rattan Art and Decorations Inc., compensability, G.R. No. L-42087, LABOR LAW