Ponce v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Zacarias Ponce was a public school teacher from August 1938 to September 9, 1974. In 1965, he contracted pulmonary tuberculosis (PTB) and was under treatment. Despite his illness, he continued teaching. On July 5, 1974, he vomited blood while conducting classes and was advised to go on leave. His optional retirement was approved effective September 9, 1974. His physician advised complete rest. A Compensation Rating Medical Officer found him suffering from moderately advanced PTB and granted him a 48% permanent partial disability rating. Procedural History: The claim for compensation was dismissed by the Hearing Officer and Acting Referee on two grounds: (a) claimant retired under Commonwealth Act 186, which prohibits granting benefits to those who retired under the Act, and (b) claimant did not lose any earning power. The Referee cited Cebu Portland Cement v. Mamerto de Jesus for the prohibition. The Workmen's Compensation Commission (Commission) en banc affirmed the Referee's decision, finding that the records failed to establish a disabling illness at the time of retirement, considering he resumed work after his leave and the x-ray was taken after retirement. The Petition: Petitioner elevated the case to the Supreme Court, arguing that the dismissal was without basis in law and jurisprudence, constituting grave abuse of discretion. He contended that benefits under the Workmen's Compensation Act are in addition to GSIS retirement benefits and that his illness resulted in loss of earning power.
Issue(s)
Whether an employee granted retirement gratuity under the GSIS law is still entitled to compensatory benefits under the Workmen's Compensation Act. Whether an employee who received retirement benefits under the GSIS law does not suffer any loss of earning power and is therefore not entitled to compensation under the Workmen's Compensation Act. Whether the Workmen's Compensation Commission, as an appellate body, can digress from the issues submitted for review and make its own findings of fact not borne by the evidence.
Ruling
The Supreme Court SET ASIDE the decision of the respondent Commission. The respondent Bureau of Public Schools was ordered to pay petitioner-claimant P6,000.00 for permanent total disability, P600.00 for attorney's fees, and P61.00 as administrative fee to the Workmen's Compensation Commission.
Ratio Decidendi
On the issue of entitlement to compensation despite receiving GSIS retirement benefits: The Court held that the Workmen's Compensation Act, as amended by R.A. No. 4119, explicitly states that employees insured with the GSIS are entitled to benefits under the Workmen's Compensation Act in addition to their GSIS benefits. Therefore, receiving retirement benefits under Commonwealth Act 186 (GSIS law) does not preclude an employee from claiming compensation under the Workmen's Compensation Act. The policy behind the Workmen's Compensation Act is to protect workmen against becoming objects of charity by providing reasonable compensation for work-related calamities. On the issue of loss of earning power: The Court found no basis for the assumption that receiving retirement benefits automatically means no loss of earning power. The evidence, including the physician's report, indicated that petitioner's pulmonary tuberculosis was work-connected and had resulted in permanent total disability. The fact that he resumed teaching after a short leave was due to the demands of the service, not because his earning capacity was unimpaired. The Court emphasized that the Workmen's Compensation Act is social legislation to be liberally interpreted in favor of employees. On the issue of the Commission's appellate jurisdiction: The Court ruled that the respondent Commission acted in excess of its authority and with grave abuse of discretion when it failed to resolve the issues presented on appeal and instead made its own findings of fact to justify the dismissal of the claim. As an appellate body, the Commission should have limited itself to reviewing the Referee's decision based on the submitted issues and evidence. The Commission's act of ignoring the issues and making new findings was capricious and whimsical, contrary to the interest of justice and applicable law.
Main Doctrine
An employee who contracts tuberculosis or other illness directly caused by, aggravated by, or the result of the nature of his employment is entitled to compensation under the Workmen's Compensation Act, even if he has already received retirement benefits under the GSIS law. The benefits under the Workmen's Compensation Act are in addition to those granted by the GSIS.