Gascon v. Employees' Compensation Commission
REITERATIONFacts
1. The Antecedents: Benigno C. Gascon, after twenty-six years of service in the Bureau of Customs, retired at the age of 64 due to contracting diabetes mellitus and pulmonary tuberculosis. He attributed these ailments to the nature and conditions of his employment as a customs examiner. Gascon began his service in June 1953 and held various positions, ultimately serving as a customs examiner I. His ailments led to significant absences from work, including a sick leave from December 2, 1974, to March 31, 1975, followed by his retirement on April 1, 1975. 2. Procedural History: Gascon filed a claim for disability benefits under Presidential Decree No. 626, as amended, with the Government Service Insurance System (GSIS) on February 9, 1976. The GSIS denied the claim, stating that the ailments were contracted prior to the advent of the new Employees' Compensation Program and thus lacked a legal basis. Subsequently, the Employees' Compensation Commission (ECC) affirmed the GSIS decision, citing two grounds: the claim was filed after the March 31, 1975 deadline for claims accrued prior to the New Labor Code, and the ECC lacked jurisdiction over such claims. This petition for review on certiorari seeks to overturn the ECC's decision. 3. The Petition: The petitioner seeks review of the ECC's decision, arguing that his claim is governed by the Workmen's Compensation Act, not the New Labor Code, as his illness commenced prior to January 1, 1975. He contends that the ten-year prescriptive period for claims under the Workmen's Compensation Act applies, and his claim, filed on February 9, 1976, was within this period. Furthermore, he asserts that the ECC, as the successor to the Workmen's Compensation Commission, has jurisdiction over claims governed by the old Act and should apply its principles, including the presumption of compensability and aggravation. The petitioner detailed how his duties as a customs examiner, involving exposure to various health conditions, poorly ventilated areas, dust, toxic substances, abrupt temperature changes, and loss of sleep, increased his risk of contracting pulmonary tuberculosis.
Issue(s)
Whether the claim for disability benefits is barred by the prescriptive period under Article 292 of the New Labor Code. Whether the Employees' Compensation Commission has jurisdiction over claims governed by the Workmen's Compensation Act, as amended.
Ruling
The decision of the Employees' Compensation Commission is SET ASIDE. The Bureau of Customs is ordered to pay petitioner P6,000.00 as disability compensation benefits, reimburse his medical and hospital expenses, and pay attorney's fees equivalent to 10% of the award.
Ratio Decidendi
On the prescriptive period: The Court held that Article 292 of the New Labor Code, which sets a March 31, 1975 deadline for filing claims accrued prior to the New Labor Code, does not apply to the petitioner's claim. Citing previous rulings in Corales v. Employees Compensation Commission, Javier v. Employees Compensation Commission, and Santarin v. Employees Compensation Commission, the Court reiterated that claims falling under the Workmen's Compensation Act but filed after March 31, 1975, are governed by a ten (10) year prescriptive period, as it is a right founded on statute. The petitioner's ailments commenced prior to 1974, and his right accrued as early as September 1965, thus constituting a vested right. When he filed his claim on February 9, 1976, the ten-year prescriptive period had not yet lapsed. The Court emphasized that the New Labor Code's provisions on Employees' Compensation apply only to injuries, sickness, disability, or death accruing on or after January 1, 1975. Therefore, the petitioner's claim, having accrued earlier, continued to be governed by the Workmen's Compensation Act. On the jurisdiction of the ECC: The Court found the ECC's conclusion that it had no jurisdiction over the petitioner's claim erroneous. As the successor of the defunct Workmen's Compensation Commission, the ECC possesses the jurisdiction to pass upon claims governed by the Workmen's Compensation Act, as amended. The Court stated that the ECC is duty-bound to apply the underlying principles of the Workmen's Compensation Act, including the presumption of compensability, the principle of aggravation, and the award of attorney's fees and administrative fees. The ECC itself admitted the linkage between the petitioner's illness and his employment, ruling that the cause of action fell under the old Workmen's Compensation Act, but incorrectly concluded this placed it outside the ECC's jurisdiction. The Court clarified that the ECC's role as successor mandates it to apply the old law's principles when applicable.
Main Doctrine
Claims for disability benefits that accrued under the Workmen's Compensation Act, as amended, are governed by a ten (10) year prescriptive period and are not barred by the March 31, 1975 deadline set by Article 292 of the New Labor Code. The Employees' Compensation Commission, as successor to the Workmen's Compensation Commission, has jurisdiction over such claims and is duty-bound to apply the principles of the Workmen's Compensation Act, including the presumption of compensability and the principle of aggravation.