De la Torre v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Gertrudes de la Torre was employed as a classroom teacher from June 12, 1933, until her retirement on November 15, 1973. Her work involved traveling, standing for long periods, and preparing lesson plans under an oil lamp. She became hypertensive in 1950. After almost five years from retirement, on August 21, 1978, she was hospitalized and diagnosed with essential hypertension, with symptoms manifesting a week prior. Procedural History: On February 7, 1983, due to her weakened physical state, she filed a claim for disability benefits under P.D. 626 with the Government Service Insurance System (GSIS). The GSIS denied the claim on May 14, 1983, stating it only had jurisdiction over claims of employees in service on or after January 1, 1975. The Employees' Compensation Commission (ECC) affirmed the GSIS decision on September 12, 1984, reasoning that the illness was contracted almost five years after retirement and thus not a result of employment. The Petition: Maximo de la Torre, husband of the deceased Gertrudes, filed a petition for review with the Supreme Court on October 25, 1984, seeking to set aside the ECC decision.
Issue(s)
Whether the claim for disability benefits is governed by P.D. 626 or the Workmen's Compensation Act. Whether essential hypertension contracted by a government employee during service is compensable. Whether the claim is barred by the lapse of time between retirement and the manifestation of the illness. Whether the employer-employee relationship must exist at the time of filing the claim for compensation.
Ruling
The Supreme Court reversed and set aside the decision of the Employees' Compensation Commission, ordering the Ministry of Education and Culture to pay disability compensation benefits, reimbursement for medical expenses, funeral benefits, and attorney's fees, plus administrative costs.
Ratio Decidendi
On the governing law: The Court held that since the deceased became hypertensive in 1950, her cause of action accrued during the effectivity of the Workmen's Compensation Act. Therefore, this Act, not P.D. 626, governed her claim. The Court reiterated the settled doctrine that the law in force at the time of accrual of a cause of action governs, even if a new law is enacted later. This ensures consistency and fairness in applying the law applicable at the time the right arose. The Court also found the contention that the claim was barred by prescription to be untenable. It reiterated the settled doctrine in Javier vs. ECC that claims falling under the scope of the Workmen's Compensation Act have a 10-year prescriptive period. The claim filed on February 17, 1983, was within this period from the accrual of the cause of action in 1950. On the compensability of essential hypertension: The Court applied the presumption of compensability under the Workmen's Compensation Act, stating that when a sickness supervenes during employment, it is presumed to have arisen out of or been aggravated by the work conditions. The deceased was in good health upon entering service and developed hypertension after 17 years of strenuous teaching. The Court noted that the etiology of essential hypertension is not accurately traced by medical authorities, and requiring the claimant to prove exact causation would be inconsistent with the State's policy of affording maximum aid to labor. Medical authorities indicate a relationship between stress and hypertension, and the deceased's work conditions were deemed stressful. On the lapse of time between retirement and illness manifestation: The Court clarified that the deceased contracted her essential hypertension during her employment, not five years after retirement. The worsening of the condition after retirement was immaterial, as the main consideration for compensability was that it was contracted during and by reason of her employment. The Court cited LaO vs. ECC and Caoili vs. Republic, emphasizing that compensability is not affected by extraneous factors causing or accelerating an illness, and it is sufficient that employment contributed even in a small degree. On the existence of employer-employee relationship at the time of claim: The Court rejected the contention that an employer-employee relationship must exist at the time of filing the claim. It held that rights that have already arisen are not extinguished by the cessation of the relationship. The Court cited Caoili vs. Republic, stating that if the validity of an award depended on the existence of the relationship at the time of judgment, employers could evade obligations by dismissing employees. The Court affirmed that retired employees are still entitled to compensation if the illness or injury arose out of or in the course of employment, as provided by the Workmen's Compensation Act, even concurrently with retirement benefits under the GSIS Law.
Main Doctrine
Essential hypertension contracted during employment is presumed to have arisen out of or was aggravated by the nature and conditions of work, and the claimant is relieved of the burden to show causation, with the employer bearing the burden to prove otherwise. The governing law for claims that accrued prior to the effectivity of a new law is the law in force at the time of accrual.