Poral v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Dolores P. Poral, a 55-year old teacher, experienced intense pain and blurring of vision in 1957 due to acute glaucoma, necessitating an operation. Despite surgery, she frequently missed classes due to recurring eye pain and blurred vision. In 1972, she again suffered severe pain, took a leave of absence, and underwent another operation, which provided only temporary relief. Her sight did not return to normal, leading her to apply for retirement benefits effective August 1977. Procedural History: The respondent Government Service Insurance System (GSIS) denied her claim for income benefits under Presidential Decree No. 626, as amended, on the ground that acute glaucoma is not an occupational disease but a common ailment of middle and advanced life. The Employees' Compensation Commission (ECC) affirmed this denial. The Petition: Petitioner filed a petition for certiorari, questioning whether a teacher's glaucoma is compensable and if such ailment is covered by the New Labor Code even if it occurred before 1975.
Issue(s)
Whether a teacher's glaucoma is compensable. Whether the ailment is covered by the Workmen's Compensation Act even if it occurred before 1975, and whether vested rights under that Act apply.
Ruling
The petition is granted. The decision of the Employees' Compensation Commission is SET ASIDE. The Ministry of Education, Culture and Sports is ordered to pay the petitioner P6,000.00 as disability compensation benefits and attorney's fees equivalent to ten percent (10%) of the award.
Ratio Decidendi
On whether a teacher's glaucoma is compensable: The Court held that compensation claims are viewed and treated on a much broader perspective based on the constitutional precepts of social justice and protection to labor. Under Section 44 of the Workmen's Compensation Act, a presumption of compensability is established for any ailment that occurred or was aggravated in the course of employment. This presumption is rebuttable only by substantial evidence to the contrary. In this case, the employer failed to present any evidence to rebut the presumption. The Court emphasized that the cause of the ailment is immaterial; what is important is that it occurred or was aggravated in the course of employment. Once an illness supervenes during employment, there is a rebuttable presumption that it arose out of employment or was at least aggravated by it. The Court cited Makabali vs. ECC where it stated that a teacher who continued working despite deteriorating vision should not be deprived of compensation but rewarded for devotion to duty. On whether the ailment is covered by the Workmen's Compensation Act even if it occurred before 1975, and whether vested rights under that Act apply: The Court ruled that the Workmen's Compensation Act, as amended, governs the instant case, not Presidential Decree No. 626, as amended, because the petitioner's claim accrued prior to the New Labor Code. The Court reiterated its pronouncement in Sabino vs. ECC that when a claim accrues during the effectivity of the Workmen's Compensation Act, the claimant has a vested right based on that Act. The principles governing vested rights founded on statute should apply. Therefore, the presumption of compensability, the principle of aggravation, and other benefits provided under the old Act must be observed and applied. The ECC, as successor to the Workmen's Compensation Commission, is duty-bound to apply these principles.
Main Doctrine
Under the Workmen's Compensation Act, a claim for disability benefits for an ailment that occurred or was aggravated during employment is presumed compensable, and this presumption is conclusive unless rebutted by substantial evidence. The law in force at the time the claim accrued governs, and principles of social justice and protection to labor mandate a liberal interpretation of compensation laws.