Cuenca v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Severo E. Cuenza, employed as a driver since April 21, 1950, filed a claim for disability benefits on February 5, 1976, due to an ailment diagnosed as "Neuroblastoma, Mediastinum." His symptoms, including shortness of breath, fatigability, and chest pain, began in 1972 and worsened over time, accompanied by cough and bloody expectoration. A chest x-ray revealed a mass, and subsequent surgery diagnosed it as a neurogenic tumor known as Neuroblastoma. Procedural History: The Government Service Insurance System (GSIS) denied the claim on February 25, 1976, stating the ailment was not an occupational disease and that the nature of Cuenza's duties as a driver could not have directly caused it. The Employees' Compensation Commission (ECC) affirmed the GSIS decision, finding that Cuenza's employment conditions did not increase the risk of contracting the ailment and that the ailment manifested before January 1, 1975, thus falling outside the "compensable ambit" of Presidential Decree No. 626. The Petition: Cuenza filed a petition for review with the Supreme Court, arguing that any doubt regarding the role of his employment in the development of his ailment should be resolved in his favor, given the spirit of liberality in interpreting PD 626. He also stressed that the cause of neuroblastoma is unknown.
Issue(s)
Whether the claim for disability benefits should be governed by the Workmen's Compensation Act or Presidential Decree No. 626. Whether the petitioner's ailment, Neuroblastoma, is compensable. Whether the presumption of compensability applies and was rebutted by the respondent.
Ruling
The Supreme Court set aside the decision of the Employees' Compensation Commission and ordered the Government Service Insurance System to pay Severo E. Cuenza P6,000.00 as disability benefit, reimburse his medical expenses, and pay P600.00 as attorney's fees.
Ratio Decidendi
On whether the claim should be governed by the Workmen's Compensation Act or Presidential Decree No. 626: The Court held that since the petitioner's ailment manifested in 1972, prior to January 1, 1975, the governing law is the Workmen's Compensation Act, not Presidential Decree No. 626. This is based on the principle that a cause of action that accrued under a statute in force at the time of accrual is governed by that statute, even if a new law takes effect later. The Court cited previous rulings in Balatero vs. Employees' Compensation Commission, Corrales vs. ECC, Villones vs. ECC, and De los Angeles vs. ECC to support this principle. The right to compensation had vested under the old law when the illness manifested. On whether the petitioner's ailment is compensable: The Court found that the petitioner's ailment, Neuroblastoma, supervened during his employment. Under the old Workmen's Compensation Law, when an ailment is contracted or aggravated in the course of employment, a disputable presumption of compensability arises. This means the ailment is presumed to have arisen from or been aggravated by the employment. The burden of proof then shifts to the employer to present substantial evidence to overcome this presumption. The Court reiterated the principle established in De los Angeles vs. ECC, Animos vs. WCC, and Enriquez vs. WCC. On whether the presumption of compensability was rebutted: The Court concluded that the respondent Government Service Insurance System failed to rebut the presumption of compensability. The GSIS's assertion that the ailment would have been contracted regardless of employment was deemed insufficient. The ECC's finding that the employment conditions did not increase the risk was not considered substantial evidence to overcome the legal presumption. Therefore, the claim is compensable under the Workmen's Compensation Act.
Main Doctrine
Ailments contracted during employment are presumed compensable under the Workmen's Compensation Act, and the burden shifts to the employer to prove otherwise. The governing law for claims that accrued prior to January 1, 1975, is the Workmen's Compensation Act, even if filed after the effectivity of the New Labor Code.