Reyes v. Employees' Compensation Commission
REITERATIONFacts
1. The Antecedents: Baltazar C. Reyes, formerly employed as a casual laborer and later as a Personnel Aide with the Bureau of Agricultural Extension, retired from service on August 15, 1975, due to physical disability. He attributed his illness, essential hypertension, to the strain and stress generated by his work. His claim for disability and income benefits under Presidential Decree No. 626 was filed with the Government Service Insurance System (GSIS). 2. Procedural History: The GSIS denied Reyes' claim, stating that essential hypertension is not an occupational disease and that his duties could not have directly caused the ailment, though they might have aggravated it. Reyes' request for reconsideration was denied. The case was then elevated to the Employees Compensation Commission (ECC), which affirmed the GSIS denial. The ECC concluded that the illness was likely due to the petitioner's advanced age and that aggravation of a condition is not compensable under the current program. 3. The Petition: This case is a Petition for Review on certiorari seeking to overturn the decision of the Employees Compensation Commission. The petitioner argues that his illness occurred during his employment and that, under prevailing jurisprudence, the Workmen's Compensation Act should govern his claim, as his cause of action accrued prior to the effectivity of the New Labor Code. He contends that even if his work only aggravated his condition, it is still compensable, and that the presumption of compensability applies when an illness occurs during employment, especially when the exact cause is not definitively determinable.
Issue(s)
Whether the petitioner's claim for disability benefits is governed by the Workmen's Compensation Act or the New Labor Code. Whether essential hypertension, allegedly aggravated by the nature of employment, is a compensable illness. Whether the presumption of compensability applies in this case.
Ruling
The Supreme Court set aside the decision of the Employees Compensation Commission and ordered the Government Service Insurance System to pay petitioner Baltazar C. Reyes such disability income benefits as may be due to him under the law.
Ratio Decidendi
On whether the petitioner's claim for disability benefits is governed by the Workmen's Compensation Act or the New Labor Code: The Court held that since the petitioner's illness, essential hypertension, manifested and occurred during his employment prior to January 1, 1975, the effectivity of the New Labor Code, the provisions of the Workmen's Compensation Act shall govern his claim. The accrual of a cause of action in workmen's compensation cases is determined by the date the ailment was felt, not the date of retirement. Evidence presented, including medical certificates dated March 11, 1974, and June 21, 1974, indicated that the petitioner was suffering from essential hypertension even before the New Labor Code took effect, thus placing his claim under the coverage of the Workmen's Compensation Act. The Court reiterated that all actions or claims accruing prior to the effectivity of the New Labor Code are determined in accordance with the law enforced at the time of their accrual, as provided in Article 294 of the Transitory and Final Provisions of the New Labor Code. On whether essential hypertension, allegedly aggravated by the nature of employment, is a compensable illness: The Court found the ECC's assertion that aggravation is no longer compensable under the present program untenable, especially considering that the illness began during employment and prior to the New Labor Code. The Court emphasized that under the Workmen's Compensation Act, the exact cause of the ailment is not significant, and the possibility of other factors like advancing age contributing to the ailment does not preclude compensability. What is material is that the employment contributed, even in a small degree, in aggravating the ailment. The Court cited previous rulings stating that the employment need only aggravate the condition for the claim to be compensable. On whether the presumption of compensability applies in this case: The Court affirmed the principle that even if the exact cause of the illness is unknown, so long as it occurs during employment, the presumption of compensability exists. This presumption can only be overcome by substantial evidence to the contrary. The Court noted that the ECC's Medical Officer's opinion regarding the lack of causal connection or increased risk due to working conditions could not overthrow this presumption. The Court cited Lao v. ECC to support the ruling that where the cause of illness is not definitely determinable, medical reports from the employer (ECC or GSIS) cannot prevail over the presumption of compensability and aggravation.
Main Doctrine
An illness that supervened during employment, even if not directly caused by it but merely aggravated by the nature of work, is compensable under the Workmen's Compensation Act if the cause of action accrued prior to the effectivity of the New Labor Code. The presumption of compensability exists when the illness occurs during employment, even if the exact cause is unknown.