Balatero v. Employees Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Florencio Balatero, a public school teacher and District Adult and Community Education Coordinator, experienced symptoms of dizziness, headache, and gradual hearing loss starting in 1972. By September 27, 1973, his hearing was totally impaired, diagnosed as "Hypertension with Impairment of Hearing." He retired on May 9, 1975, at age 63. Procedural History: Petitioner filed a claim for compensation benefits under P.D. No. 626 with the GSIS, which was denied on the grounds that his ailment was not directly caused by his work and was merely aggravated, and that aggravation was not compensable under the new program. The GSIS also questioned its jurisdiction, stating the ailment's onset was in 1972, prior to January 1, 1975, the effectivity date for compensability under P.D. No. 626. The Employees Compensation Commission (ECC) affirmed the GSIS denial, citing lack of evidence and the onset of ailment prior to the new law's effectivity, suggesting the ailment was presbycusis due to aging. The Petition: Petitioner sought review of the ECC's decision, arguing that the governing law should be the Workmen's Compensation Law, which was in effect when his cause of action accrued in 1972. He contended that his ailments were contracted or aggravated by his employment, triggering the presumption of compensability.
Issue(s)
Whether the Workmen's Compensation Law, rather than P.D. No. 626, governs the claim. Whether the petitioner's ailments (hypertension and impairment of hearing) are compensable under the applicable law. Whether the petitioner's retirement due to his ailments establishes his disability.
Ruling
The Supreme Court ruled in favor of the petitioner, setting aside the decision of the Employees' Compensation Commission. The GSIS was ordered to pay disability compensation benefits, reimburse medical expenses, and pay attorney's fees and administrative costs.
Ratio Decidendi
On whether the Workmen's Compensation Law governs the claim: The Court held that the Workmen's Compensation Law should govern because the cause of action, the onset of the ailments, existed as early as 1972, prior to the effectivity of P.D. No. 626 on January 1, 1975. The principle that rights accrued under a statute survive its repeal was applied, meaning the petitioner's claim should be evaluated under the law in force at the time his illness began. The Court also noted that filing the claim with the GSIS instead of the appropriate regional office does not militate against the claim, as it can be treated as filed within the period allowed by law, citing Corrales vs. ECC. On whether the petitioner's ailments are compensable: The Court found merit in the petition, stating that it is undisputed that the petitioner's ailments supervened in the course of his employment. The respondents admitted that the ailments were at most aggravated by his work. Under the old Workmen's Compensation Law, such a showing creates a presumption of compensability, shifting the burden to the employer to prove that the illness did not arise from or was not aggravated by the employment. The Court emphasized that the petitioner's duties involved strenuous physical activities outside the classroom, exposing him to elements that could have caused his ailments, including high fever and colds leading to hearing impairment. The Court reiterated that even if advancing age is a contributing factor, the employment's strain and exertion can also be aggravating causes rendering the ailment compensable, as stated in Bautista vs. WCC. The spirit of social justice mandates that the employment's contribution, even if small, to aggravating the ailment is material and decisive. On whether the petitioner's retirement establishes his disability: The Court affirmed that the petitioner's retirement at age 63, two years before the compulsory retirement age, due to the disabling effects of his ailments, places the fact of his disability beyond question. The Court highlighted that the petitioner's need to go to remote places for his duties as District Adult Coordinator exposed him to elements that brought about his ailments, forcing him to retire early. This fact should have been given weight. The Court also referenced Republic Act No. 4670, the "Magna Charta for Public School Teachers," which states that the effects of physical and nervous strain on a teacher's health shall be recognized as compensable occupational diseases.
Main Doctrine
Under the old Workmen's Compensation Law, when an ailment is shown to have been contracted or aggravated in the course of employment, a presumption of compensability arises, shifting the burden to the employer to prove otherwise. Advancing age alone does not preclude compensability if employment exertion contributed to the ailment.