Javier v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Angelina Javier, a retired elementary school teacher, began experiencing health issues in the early '60s, including eye pain, severe headaches, and elevated blood pressure. In 1966, her assignment to a teacher-in-charge role at a school lunch counter exposed her to heat and wet conditions, leading to swelling in her extremities and difficulty walking. By May 1972, she exhibited behavioral changes, paranoia, and compulsive tendencies. She was diagnosed with paranoid schizophrenia, malignant hypertension, rheumatoid arthritis, and bilateral cataract. She was confined at Pagtanac Medical Clinic and subsequently retired from service on November 6, 1972, due to her failure to report for duty after a one-year leave of absence. Procedural History: On September 1, 1980, petitioner, through her legal guardian, filed a claim for disability compensation benefits with the GSIS under PD 626, as amended. The GSIS denied the claim due to lack of jurisdiction, stating that claims for government employees who retired before January 1, 1975, were not covered by the decree. The Employees' Compensation Commission (ECC) affirmed the GSIS decision on February 25, 1982. The Petition: Petitioner sought review of the ECC's decision, arguing that since her illness started during the effectivity of the Workmen's Compensation Act, the ten-year prescriptive period under that Act should apply. Respondents contended that under Article 292 of the Labor Code, claims accruing prior to its effectivity must be filed by March 31, 1975, to be decided under the Workmen's Compensation Act.
Issue(s)
Whether the petitioner's claim for disability benefits is governed by the Workmen's Compensation Act or the Labor Code, and whether it is barred by prescription.
Ruling
The petition is granted. The decision of the respondent Employees' Compensation Commission is set aside. The Government Service Insurance System is ordered to pay the petitioner disability compensation benefits, reimburse her medical expenses, and pay her counsel's attorney's fees.
Ratio Decidendi
On the governing law and prescription period: The Court held that the petitioner's claim for disability benefits is governed by the Workmen's Compensation Act, not the Labor Code, because her illness accrued prior to the effectivity of the latter. The Court reiterated its ruling in Corales v. Employees Compensation Commission that claims accruing prior to the New Labor Code are governed by the law in force at the time of accrual. Since the Workmen's Compensation Act was in effect when petitioner's ailments began, its provisions, including the ten-year prescriptive period, should apply. The Court emphasized that the right to file a claim under the Workmen's Compensation Act is a vested right, founded on statute, and ordinarily survives the repeal of the statute. The repeal of a statute does not impair or affect rights that have been vested or accrued while the statute was in force. Therefore, the petitioner's claim, filed eight years after her retirement in 1972, clearly fell within the ten-year prescriptive period. The Court noted that the March 31, 1975 deadline for filing claims under the new compensation law overlooked the vested rights of claimants under the previous law and jurisprudence, which recognized a ten-year prescriptive period. To sustain the ECC's stand would render a vested right worthless without a forum to enforce it, which would be contrary to the social justice guarantee of the Constitution. The Court also cited Villones v. Employees' Compensation Commission to support the principle that the law in force at the time of accrual governs the cause of action.
Main Doctrine
Claims for disability benefits that accrued prior to the effectivity of the Labor Code are governed by the Workmen's Compensation Act, and the ten-year prescriptive period provided therein applies, as the right to file such claims is a vested right that survives the repeal of the statute.