Najera v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Norma B. Najera, employed as a ward nurse, was diagnosed with cancer of the cervix (adenocarcinoma) in 1973. She underwent surgery and cobalt and radium treatment. In June 1975, she became unable to work and was hospitalized for recto-vaginal fistula, a complication of the cervical cancer and radiation therapy. She underwent sigmoid colostomy. Procedural History: Petitioner filed a claim for benefits under Presidential Decree No. 626 (PD 626) with the Government Service Insurance System (GSIS), which was denied on the ground that her ailment was not a direct result of her duties nor was the risk increased by her working conditions. The GSIS denied reconsideration, stating the ailment was not peculiar to her work. Petitioner appealed to the Employees' Compensation Commission (ECC). Petitioner died on March 10, 1976, due to adenocarcinoma of the cervix. On March 31, 1976, the ECC affirmed the GSIS decision. The Petition: Petitioner's husband, Manuel Najera, obtained a copy of the ECC decision on December 5, 1979, and filed a petition for review with the Supreme Court on December 14, 1979, raising issues regarding the reasonableness of PD 626, the applicability of the presumption of compensability, and the compensability of the disability and death.
Issue(s)
Whether Presidential Decree No. 626, as amended, is reasonable and just, upholding due process and equal protection. Whether the doctrine of presumption of compensability is still applicable to the petitioner's claim. Whether the petitioner's disability and subsequent death are compensable.
Ruling
The Supreme Court reversed and set aside the decision of the Employees' Compensation Commission. It directed the National Orthopedic Hospital to pay compensation benefits, refund medical and hospital expenses, and pay administrative costs.
Ratio Decidendi
On Presidential Decree No. 626: The Court held that the determination of which law applies—the Workmen's Compensation Act or the New Labor Code—is the main issue. It found that Norma Najera's illness supervened in 1973, prior to the effectivity of the New Labor Code on January 1, 1975. Therefore, her claim should be decided under the Workmen's Compensation Act. The Court reiterated its ruling in Corrales vs. ECC that claims with onset prior to January 1, 1975, are governed by the Workmen's Compensation Act, and filing after March 31, 1975, does not bar the claim as the prescriptive period is 10 years. The Court also affirmed that filing with the GSIS instead of the Department of Labor's regional office does not prejudice the claim. Consequently, the provisions on the presumption of compensability, presumption of work-connection or work-aggravation, waiver of non-jurisdictional defenses due to non-controversion, and the 10-year prescriptive period under the Workmen's Compensation Act apply. On the presumption of compensability: The Court noted that the fact that Norma was healthy at the time of employment and her illness supervened during employment was not controverted by her employer, and no proof of controversion was disclosed. Under the Workmen's Compensation Act, this freed the claimant from proving causation or aggravation by the nature of her work. The rebuttable presumption of compensability shifted the burden to the employer to overcome it with substantial evidence, which the employer failed to do. The Court emphasized that the Workmen's Compensation Act is social legislation designed to provide relief to the working man and must be liberally construed. The medical opinion suggesting it was unlikely that the claimant's occupation had any relation to her illness could not prevail over the presumption established by law, citing Villasan vs. Republic and Flores vs. WCC. On the compensability of the claim: Given that the claim is governed by the Workmen's Compensation Act and the presumption of compensability applies, the Court found that the petitioner's disability and subsequent death were compensable. The employer failed to discharge its burden of proving that the illness was not work-related or aggravated. The Court concluded that the medical opinion presented was insufficient to overcome the legal presumption of compensability. Therefore, the denial of the claim by the GSIS and the affirmation by the ECC were reversed.
Main Doctrine
Claims for compensation that have their onset prior to January 1, 1975, shall be decided under the Workmen's Compensation Act, even if filed after March 31, 1975, as the prescriptive period is 10 years. The presumption of compensability under the Workmen's Compensation Act shifts the burden of proof to the employer, and medical opinions unlikely to relate the occupation to the illness cannot prevail over this presumption.