Caneja v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Francisco Cañeja, a classroom teacher, had several interruptions in his government service between November 1959 and July 1974 due to schizophrenia. He was confined at the National Mental Hospital multiple times and received outpatient treatment. His illness caused him to be out of work and destitute. There were discrepancies regarding the exact dates of his service interruptions and retirement. Procedural History: Petitioner filed a claim for income benefits under P.D. No. 626 with the GSIS on July 30, 1976. The GSIS denied the claim on August 4, 1976, stating that schizophrenia is not an occupational disease. Reconsideration was also denied. The case was forwarded to the Employees' Compensation Commission (ECC), which affirmed the GSIS denial on April 21, 1977. The Petition: Petitioner sought review of the ECC decision, arguing that his illness was work-connected and that his claim had not prescribed.
Issue(s)
Whether the petitioner's illness, schizophrenia, is compensable under the law. Whether the petitioner's claim for compensation has prescribed.
Ruling
The decision of the respondent Employees' Compensation Commission is set aside. The Government Service Insurance System is ordered to pay petitioner disability compensation benefits, reimburse medical expenses, pay attorney's fees, and administrative costs.
Ratio Decidendi
On the compensability of the illness: The Court held that the petitioner's illness, schizophrenia, supervened in the course of employment. Under the Workmen's Compensation Act, there is a rebuttable presumption that such an illness either arose out of or was aggravated by the nature of the employment. The employer failed to present substantial evidence to overcome this presumption. The Court emphasized that the cause of the ailment is immaterial; what is important is that it occurred or was aggravated during employment and disabled the workman. The presumption of compensability becomes conclusive upon the employer's failure to rebut it, as stated in Enriquez vs. WCC, et al.. On the prescription of the claim: The Court ruled that claims under the Workmen's Compensation Act, as amended, prescribe in ten (10) years pursuant to Act 1144(2) of the Civil Code. This ten-year period commences from the time the employee becomes disabled to pursue his occupation. Given the petitioner's disability in 1972-1973, the claim filed on July 30, 1976, was well within the prescriptive period. The Court also cited GB Francisco, Inc. vs. WCC and Ybanez vs. WCC to support the ten-year prescriptive period. The Court further noted that the disability in 1972-1973 could be treated as a separate liability, bolstered by the doctrine in Earnshaw Docks, et al. vs. Sortijas, where re-employment of a disabled employee implies acceptance of the risk of future disability.
Main Doctrine
An illness that supervened in the course of employment is presumed to have arisen out of or at least been aggravated by the nature of the employment, and the burden to prove otherwise lies with the employer. Claims under the Workmen's Compensation Act prescribe in ten (10) years from the date of disability.