Sabino v. Employees’ Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Cucufata A. Sabino, a public school teacher from June 14, 1963, to July 6, 1981, filed a claim for disability compensation due to visual defects (retinitis pigmentosa and bilateral glaucoma OS absolute) which caused her complete blindness. As early as 1972, she experienced episodes of dimness of vision. Procedural History: The Government Service Insurance System (GSIS) denied the claim, stating the illnesses were not occupational diseases under P.D. No. 626 and her position did not increase the risk of contracting them. The GSIS denied her motion for reconsideration, applying the new Labor Code. The Employees’ Compensation Commission (ECC) affirmed the GSIS decision, citing medical literature on glaucoma and retinitis pigmentosa, and stating that the theory of aggravation and presumption of compensability under the Workmen's Compensation Act were no longer applicable under the new Labor Code. The Petition: Petitioner seeks review of the ECC decision, raising issues on the applicable law (old Workmen's Compensation Act vs. new Labor Code) and the applicability of the principles of presumption of compensability and aggravation rule.
Issue(s)
Whether the ailments of petitioner which accrued in 1972 and gradually developed until her forced retirement on June 6, 1981, should be decided under the provisions of the old Workmen's Compensation Act, as amended, or under the new Labor Code on Employees’ Compensation Law, P.D. 626, as amended; and whether the principles of presumption of compensability and aggravation rule are applicable to the claim of petitioner. Whether the petitioner's continued work despite her ailments should affect her claim for compensation.
Ruling
The decision of the Employees’ Compensation Commission is SET ASIDE. The Ministry of Education, Culture and Sports is ordered to pay petitioner disability compensation benefits, reimburse medical and hospital expenses, and pay attorney's fees.
Ratio Decidendi
On the applicable law, principles, and their applicability to the claim: The Court held that the Workmen's Compensation Act, as amended, governs the instant case, not P.D. No. 626, as amended, based on the principle that statutes governing vested rights should apply. The Court reiterated rulings in Corales v. ECC, Lao v. ECC, and Panangui, Et. Al. v. ECC, establishing that claims accruing prior to the New Labor Code are subject to the presumption of compensability, the principle of aggravation, and other benefits under the old law. The ECC, as successor to the Workmen's Compensation Commission, is duty-bound to apply these principles. The presumption of compensability under Section 44 of the Workmen's Compensation Act places the burden on the employer to prove otherwise with substantial evidence, and in the absence of such evidence, the presumption becomes conclusive, as held in Segismundo v. GSIS. The cause of the ailment is immaterial if it occurred or was aggravated during employment, as stated in Evangelista v. ECC. On the effect of the petitioner's continued work on her claim: The Court found that the petitioner's illness started in 1972, and her failure to stop working then did not negate her condition. The ruling in Makabali v. ECC was applied, where a teacher who continued working despite deteriorating vision was deemed entitled to compensation. Therefore, the petitioner should not be deprived of her compensation due to her devotion to her duties; her continued work despite deteriorating vision, as seen in the Makabali v. ECC case, should not deprive her of compensation but rather be rewarded, applying the same presumption in her favor.
Main Doctrine
Claims that accrued prior to the effectivity of the New Labor Code are governed by the Workmen's Compensation Act, as amended, and are entitled to the benefits of the presumption of compensability and the principle of aggravation.