Cedo v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Josefina Cedo, a public school teacher, was assigned to remote areas requiring arduous travel. She was diagnosed with viral pneumonia on December 9, 1977. While still suffering from pneumonia, she was operated on for appendicitis on December 27, 1977, due to severe abdominal pains. Her recovery was complicated by fever and severe coughing from the pneumonia, causing the surgical wound to heal slowly. Procedural History: Cedo filed a claim for benefits under P.D. No. 626, as amended, with the Government Service Insurance System (GSIS), which denied the claim, stating viral pneumonia and appendicitis were not compensable. On appeal, the Employees' Compensation Commission (ECC) granted temporary disability benefits for viral pneumonia for a specific period but denied benefits for the appendicitis operation. The Petition: Cedo filed a petition for review with the Supreme Court, seeking to modify the ECC's decision to include benefits for the appendicitis operation and the extended period of disability. The core of her petition was that the appendicitis and its complications were directly caused or aggravated by her compensable viral pneumonia.
Issue(s)
Whether the disability arising from the appendicitis operation is compensable when it occurred while the petitioner was suffering from a compensable illness (viral pneumonia) and was aggravated by the symptoms of that illness. Whether the petitioner is entitled to disability benefits for one (1) year and reimbursement of medical expenses.
Ruling
The Supreme Court modified the decision of the Employees' Compensation Commission. The Government Service Insurance System (GSIS) was ordered to pay the petitioner P3,000.00 as attorney's fees and to reimburse her for medical expenses supported by proper receipts. The Court implicitly affirmed the compensability of the appendicitis operation and the extended disability due to its aggravation by viral pneumonia, and awarded benefits for one year.
Ratio Decidendi
On Whether the disability arising from the appendicitis operation is compensable when it occurred while the petitioner was suffering from a compensable illness (viral pneumonia) and was aggravated by the symptoms of that illness: The Court found that it was a fact that the petitioner was still sick with viral pneumonia when she underwent the operation for inflamed appendicitis. It was also established that the operation for inflamed appendicitis was directly caused or aggravated by her illness of viral pneumonia, which was found to be compensable by the ECC. Furthermore, the Court noted that due to the petitioner's fever and severe coughing, which were symptoms of the viral pneumonia, the operated wound failed to heal during its normal period, leading to prolonged disability. This chain of events established a causal link between the compensable illness and the subsequent complications and extended disability, making them compensable. On Whether the petitioner is entitled to disability benefits for one (1) year and reimbursement of medical expenses: The Court affirmed that the petitioner was entitled to disability benefits for one (1) year and reimbursement of medical expenses incurred for her illness. The Court cited Article 192, Sub-section (c) of the Labor Code, as amended by Presidential Decree No. 1368, which states that a temporary total disability continuously lasting for more than one hundred twenty (120) days should be considered as permanent total disability. Given that the petitioner was disabled for three hundred fifty-three (353) days, she qualified for permanent total disability benefits. The Court also calculated the benefit amount based on her average monthly salary credit and awarded her P3,000.00 in round figures, in addition to reimbursement for medical expenses.
Main Doctrine
The Employees' Compensation Commission may grant temporary disability benefits for illnesses proven to be work-related or aggravated by employment. If a subsequent condition, such as an operation for appendicitis, is directly caused or aggravated by a compensable illness (viral pneumonia), the disability arising from the operation is also compensable. Moreover, a temporary total disability continuously lasting for more than one hundred twenty (120) days is deemed permanent total disability under Article 192(c) of the Labor Code, as amended.