Santarin v. Employees’ Compensation Commission
REITERATIONFacts
The Antecedents: The late Demetrio Santarin, employed as a helper-filer for over thirteen years, suffered from asthma for approximately twenty years prior to his death. His duties involved bundling publications, carrying files and vouchers, and operating mimeograph and xerox machines. On November 10, 1975, while at work, he experienced acute respiratory distress, and he died on November 13, 1975, from cor pulmonale due to chronic obstructive lung disease, likely status asthmaticus, complicated by pneumonitis. Procedural History: The petitioner filed a claim for employee's compensation benefits, which was denied by the Government Service Insurance System (GSIS) on March 2, 1976, on the grounds that the deceased's ailments were not occupational diseases under the new Labor Code and that his employment merely aggravated a pre-existing condition. The Employees' Compensation Commission (ECC) affirmed the GSIS's decision on March 15, 1976, reiterating that the ailments were not directly caused by his employment, which had begun after the onset of his asthma. The Petition: This petition for review seeks to reverse the ECC's decision. The petitioner argues that her claim should be governed by the former Workmen's Compensation Act, as amended, because the deceased's illness accrued prior to January 1, 1975, the effective date of the new Labor Code's provisions on Employees' Compensation. She contends that under the former Act, the presumption of compensability and the principle of aggravation apply, making her claim valid. The petition relies on previous Supreme Court rulings that established the applicability of the old law for claims accrued before its enactment and the ten-year prescriptive period for such claims.
Issue(s)
Whether the claim for employee's compensation is governed by the former Workmen’s Compensation Act, as amended, or by the provisions on Employees’ Compensation and State Insurance Fund found in Title Two of the Labor Code. Whether the death of the deceased, Demetrio Santarin, from status asthmaticus and pneumonitis, aggravated by his employment, is compensable.
Ruling
The Supreme Court reversed and set aside the decision of the Employees’ Compensation Commission. The GSIS was ordered to pay the petitioner death compensation, burial expenses, and attorney's fees.
Ratio Decidendi
On whether the claim is governed by the former Workmen’s Compensation Act or the new Labor Code: The Court held that claims for employee's compensation that accrued prior to the New Labor Code are governed by the former Workmen’s Compensation Act, as amended. This is because Article 208 of the New Labor Code states that its provisions on Employees’ Compensation apply only to injury, sickness, disability, or death accruing on or after January 1, 1975. Furthermore, Section 1(c) of Rule III of the Amended Rules on Employees Compensation clarifies that only injury or sickness that accrued on or after January 1, 1976, and the resulting disability or death, shall be compensable under those Rules. In this case, the deceased had been suffering from asthma for approximately 20 years before his death in 1975, meaning his ailment had its onset long before the effectivity of the New Labor Code. Therefore, the governing law is the Workmen’s Compensation Act, as amended. On the compensability of the death due to aggravation of a pre-existing illness: Applying the former Workmen’s Compensation Act, the Court reiterated the rule on aggravation of pre-existing illnesses. Under this law, if the employment merely aggravated a pre-existing illness, the resulting death is compensable. The Court noted that the deceased had been suffering from asthma for about twenty years prior to his death and had contracted the ailment long before he joined the government service. However, the nature of his employment as a helper-filer, which involved tasks like bundling publications and carrying files, could have aggravated his condition. The attending physician's negative answer to whether the illness was directly caused by the duties does not preclude compensability under the aggravation rule of the former Act. The Court cited previous rulings, such as Corales v. Employees Compensation Commission and Javier v. Employees Compensation Commission, which affirmed that claims accruing under the Workmen’s Compensation Act are subject to its provisions, including the presumption of compensability and the principle of aggravation.
Main Doctrine
Claims for employee's compensation that accrued prior to the New Labor Code are governed by the former Workmen’s Compensation Act, as amended, which includes the presumption of compensability and the rule on aggravation of pre-existing illnesses.