Barrameda v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Jose E. Barrameda, a 58-year old former Branch Manager of the Philippine National Bank (PNB), served the government for over 27 years. He was diagnosed with a benign lung tumor and underwent surgery on July 4, 1974. He returned to work but was unable to cope due to fatigue and general body weakness, leading to his disability retirement on March 8, 1976. Procedural History: Petitioner filed a claim for income benefits with the Government Service Insurance System (GSIS) on December 14, 1977, under the New Labor Code. The GSIS denied the claim, stating the ailment was not occupational and treatment predated PD 626. The Employees' Compensation Commission (ECC) affirmed the GSIS denial, finding no causal relationship between the ailment and employment and noting the illness was contracted before PD 626's effectivity. The Petition: Petitioner sought review of the ECC's decision, arguing his ailment was caused by his employment, particularly handling dusty bills. The GSIS, in its comment to the Supreme Court, reversed its position and admitted the validity of petitioner's claim, citing jurisprudence that claims accruing prior to PD 626 are governed by the old Workmen's Compensation Act.
Issue(s)
Whether the claim for income benefits for disability is governed by the old Workmen's Compensation Act or Presidential Decree No. 626, as amended. Whether the petitioner's lung tumor is an occupational disease or is compensable under the applicable law. Whether the petitioner is entitled to disability benefits and reimbursement of medical expenses.
Ruling
The Supreme Court set aside the decision of the Employees' Compensation Commission and ordered the Government Service Insurance System to pay petitioner disability benefits, attorney's fees, and reimburse medical expenses.
Ratio Decidendi
On whether the claim is governed by the old Workmen's Compensation Act or PD 626: The Court held that the claim is governed by the old Workmen's Compensation Act because the petitioner's illness accrued on June 1, 1974, which was prior to the effectivity of PD 626 on January 1, 1975. Applying the principle that rights accrued under a statute survive its repeal, the governing law is that in force at the time of the accrual of the cause of action. The GSIS's initial denial and the ECC's affirmation were based on the erroneous application of PD 626. The Court noted the GSIS's subsequent admission of the claim's validity, aligning with established jurisprudence on claims predating the new law. The ten-year prescriptive period under the old Act was also applicable, and the claim was filed within this period. On whether the petitioner's lung tumor is an occupational disease or is compensable: The Court, referencing the GSIS's revised stance and established doctrines, applied the presumption of compensability. Under the Workmen's Compensation Act, once an illness is shown to have supervened in the course of employment, there is a rebuttable presumption that it arose out of or was aggravated by the employment. The burden shifts to the employer to prove otherwise. The Court found that the petitioner's illness occurred during his employment, and the GSIS failed to present substantial evidence to overcome the presumption. The nature of his work, including handling dusty bills, was considered a potential factor, and the liberal construction of labor laws in favor of the workingman was invoked. On whether the petitioner is entitled to disability benefits and reimbursement of medical expenses: The Court affirmed the petitioner's entitlement to disability benefits. It noted that the petitioner was compelled to retire at age 58 due to physical incapacity, as evidenced by the approval of his optional retirement, which requires proof of such incapacity. Citing Cayaba v. WCC and Republic of the Philippines v. Follosco & WCC, the Court awarded the maximum sum of P6,000.00 as disability benefits, considering the petitioner was forced to retire prematurely and would have continued working for several more years. Reimbursement for medical expenses duly supported by receipts was also granted.
Main Doctrine
Claims for income benefits for disability that accrued prior to the effectivity of Presidential Decree No. 626, as amended, shall be governed by the provisions of the old Workmen's Compensation Act, and the ten-year prescriptive period for filing such claims is applicable.