Roque v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Roque Zozobrado, a civil engineer, worked for the Bureau of Public Highways and later the Ministry of Public Works from October 20, 1958, until his retirement on September 1, 1979. During his tenure, he held various positions, culminating in District Engineer. He retired at age 63 due to glaucoma and cataracts, ailments for which he had undergone operations in 1967, 1970, and 1978. Procedural History: Petitioner Zozobrado filed a claim for disability benefits with the Government Service Insurance System (GSIS) based on his eye conditions. The GSIS denied the claim on February 2, 1981, stating that glaucoma and cataract are not occupational diseases under Presidential Decree No. 626. After the GSIS reiterated its denial on September 23, 1981, despite Zozobrado's argument that his work involved constant visual strain, he appealed to the Employees' Compensation Commission (ECC). The ECC affirmed the GSIS decision on July 21, 1983, concluding that senile cataract is an age-related ailment and not an occupational disease, and that Zozobrado's work did not increase his risk of contracting it. The Petition: Petitioner Zozobrado seeks review of the ECC's decision via a Petition for Review on certiorari. He argues that his eye ailments, specifically cataract, should be considered compensable, contending that his work as a District Engineer, which required constant use of his vision for reviewing plans, specifications, and other project-related documents, increased the risk of developing these conditions. The petition challenges the ECC's interpretation of Presidential Decree No. 626, as amended, which requires proof that the risk of contracting a non-occupational disease is increased by working conditions, and asserts that the prior doctrine of presumptive compensability should apply.
Issue(s)
Whether the petitioner's claim for disability benefits due to glaucoma and cataract is compensable under Presidential Decree No. 626, as amended. Whether senile cataract is an occupational disease or if its risk is increased by the petitioner's working conditions.
Ruling
The Supreme Court affirmed the decision of the Employees' Compensation Commission, denying the petitioner's claim for disability benefits. The Court held that senile cataract is not an occupational disease and its risk is not increased by the nature of the petitioner's employment.
Ratio Decidendi
On the compensability of the claim under P.D. 626: The Court reiterated that under Presidential Decree No. 626, as amended, the doctrine of presumptive compensability under the old Workmen's Compensation Law has been abandoned. For sickness to be compensable, it must be an occupational disease listed under Annex 'A' of the rules with its conditions satisfied, or the claimant must prove by substantial evidence that the risk of contracting the disease is increased by the working conditions. The petitioner failed to meet either of these requirements. On senile cataract as an occupational disease and increased risk: The Court explained that senile cataract is an opacification of the lens due to morphologic and metabolic changes undergone by the aging lens, primarily associated with aging. It is not listed as an occupational disease under the rules. The petitioner's averment that his work entailed constant use of vision in reviewing plans and other duties was found insufficient to establish proof that his risk of developing cataract was increased by his working conditions. The Court emphasized that senile cataract is a risk to which all persons are exposed regardless of employment, being attributed to degenerative changes or the aging process. The findings of the Medical Division of the ECC also failed to indicate a causal link between the petitioner's duties and his contracted ailment.
Main Doctrine
Under Presidential Decree No. 626, as amended, for sickness to be compensable, it must be an occupational disease listed under Annex 'A' with its conditions satisfied, or the claimant must prove by substantial evidence that the risk of contracting the disease is increased by the working conditions. Senile cataract, being a result of the aging process, is not an occupational disease and its risk is not increased by employment conditions.