Makabali v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Paz L. Makabali, a classroom teacher, developed glaucoma during her employment. Her illness reportedly began in 1971 with headaches and blurred vision. In August 1972, she collapsed while teaching, hitting her head, after which her symptoms of recurring headaches and painful eyes intensified. She was treated for glaucoma and, due to the ailment, was forced to retire on disability in August 1975. Procedural History: Following her retirement, petitioner filed a claim for disability benefits under P.D. No. 626, as amended, with the Government Service Insurance System (GSIS). The GSIS denied her claim on June 5, 1978, stating that glaucoma is not an occupational disease and that she failed to establish a direct causal relationship between her employment and the ailment. After her request for reconsideration was denied, the case was elevated to the Employees' Compensation Commission (ECC). On August 9, 1979, the ECC affirmed the GSIS's denial, finding that the petitioner had not presented sufficient proof to establish a causal link between her occupation and the contraction of glaucoma. The Petition: Petitioner seeks review of the ECC's decision, arguing that her cause of action accrued in 1971, making the Workmen's Compensation Act, not P.D. No. 626, the applicable law. She contends that her illness, glaucoma, was aggravated by her working conditions as a teacher, particularly given the demanding nature of her job and the poor conditions in rural areas where she often taught. The respondents maintain that P.D. No. 626 applies as her claim was filed after its effectivity and that she continued working after 1971, thus not being disabled at that time. The petition further argues that the incident where she collapsed in 1972 led to the discovery of her ailment, which predated the New Labor Code, thus invoking the presumption of compensability and the principle of aggravation under the older law.
Issue(s)
Whether the Workmen's Compensation Act or P.D. No. 626, as amended, applies to the petitioner's claim. Whether the petitioner's ailment, glaucoma, is compensable under the applicable law. Whether the presumption of compensability and the principle of aggravation apply to the petitioner's claim.
Ruling
The Supreme Court ruled in favor of the petitioner, setting aside the decision of the Employees' Compensation Commission. The Ministry of Education and Culture was ordered to pay disability compensation benefits, reimburse medical expenses, furnish rehabilitation services, and pay attorney's fees and administrative costs.
Ratio Decidendi
On the applicable law: The Court held that the applicability of the Workmen's Compensation Act or P.D. No. 626 hinges on the accrual of the cause of action, determined by the onset or aggravation of the ailment. Citing Corales vs. ECC, the Court found that the petitioner's ailment manifested in 1971 and was aggravated in 1972, predating the effectivity of the New Labor Code (January 1, 1975). Therefore, the Workmen's Compensation Act, as amended, governs the claim, not P.D. No. 626. The Court rejected the respondents' argument that the claim could not have accrued in 1971 because the petitioner continued working, explaining that disability compensation does not solely depend on the loss or diminution of salary, and an employee may continue working despite medical disability due to determination. On the compensability of glaucoma: The Court found the petitioner's glaucoma to be compensable. While acknowledging that glaucoma is not listed as an occupational disease, the Court emphasized that under the Workmen's Compensation Act, there is a presumption of compensability once an illness supervenes during employment. The Court noted that the petitioner served for almost 29 years, with a significant portion of her service in rural areas with poor working conditions. Medical authorities cited indicated that glaucoma is insidious and may not be noticed until significantly advanced, and that work strain on the eyes could have contributed significantly to aggravating the condition. The Court also highlighted that Republic Act No. 4670 mandates that the effects of physical and nervous strain on a teacher's health shall be recognized as compensable occupational diseases. On the presumption of compensability and aggravation: The Court reiterated that under Section 44 of the Workmen's Compensation Act, there is a rebuttable presumption of compensability, placing the burden on the employer to prove otherwise with substantial evidence. The Court found no substantial evidence presented by the respondents to rebut this presumption. The Court further stated that the cause of the ailment is immaterial if it occurred or was aggravated during employment, and once an illness supervenes during employment, there is a rebuttable presumption that it arose out of or was aggravated by such employment. The medical findings of the respondents, which were based on predisposing factors of a different type of glaucoma, were deemed insufficient to overcome this presumption.
Main Doctrine
The applicability of the Workmen's Compensation Act or P.D. No. 626 depends on the accrual of the cause of action, which is determined by the onset of the ailment or its aggravation. If the ailment manifested or was aggravated prior to January 1, 1975, the Workmen's Compensation Act applies, carrying with it the presumption of compensability and the principle of aggravation. The fact that an employee continued working despite a diagnosed disability does not negate the claim for compensation, as disability can be medical or wage-loss related, and Section 13 of the Workmen's Compensation Act does not require wage-loss for medical expense awards.