Rosales v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Nonato Rosales, an employee of the Development Bank of the Philippines, was diagnosed with Rheumatoid Arthritis and was confined in the hospital. Following his disability, he filed a claim for employees' compensation under Presidential Decree No. 626. Procedural History: The Government Service Insurance System (GSIS) denied petitioner's claim. Petitioner's subsequent motions for reconsideration were also denied. Upon appeal to the Employees' Compensation Commission (ECC), the denial was affirmed in toto. The Petition: Petitioner assailed the ECC's decision, arguing that the ECC acted with grave abuse of discretion in declaring Rheumatoid Arthritis as not an occupational disease and that he failed to offer substantial proof that the disease arose from or was aggravated by his employment. He also contended that the ECC acted in excess of its jurisdiction in denying his claim.
Issue(s)
Whether the respondent Commission acted with grave abuse of discretion in declaring that petitioner's ailment, diagnosed as 'Rheumatoid Arthritis,' is not an occupational disease, and whether the petitioner failed to offer substantial proofs to show that such disease arose or was aggravated in the course of his employment due to working conditions. Whether the respondent Commission acted in excess of its jurisdiction in denying altogether petitioner's compensation benefits, considering the applicability of Presidential Decree No. 626.
Ruling
The petition is denied. The decision of the Employees' Compensation Commission affirming the denial of petitioner's claim for compensation benefits is sustained.
Ratio Decidendi
On the issue of Rheumatoid Arthritis as an occupational disease and the failure to prove aggravation due to working conditions: The Court affirmed the ECC's ruling that Rheumatoid Arthritis is not an occupational disease and that the petitioner failed to discharge the burden of proof required under Presidential Decree No. 626. The law requires that for an illness to be compensable, it must either be an occupational disease listed by the Commission or an illness caused by employment, with the employee proving that the risk of contracting it was increased by working conditions. The ECC correctly noted the "miserable failure of the appellant to discharge the burden required of him by the new law on employees' compensation." The claimant must present substantial evidence to support the claim, which was absent in this case. The ECC cannot grant favorable reflection on a claim clearly lacking support in evidence, as this is a mandatory requisite under PD No. 626 for finding the ailment as occupational or a result of working conditions. On the issue of the applicability of Presidential Decree No. 626 and the denial of compensation benefits: The Court reiterated that the governing law in workmen's compensation cases is determined by the date the claimant contracted the illness. Since the petitioner filed his claim under PD No. 626, which took effect on January 1, 1975, and there was no allegation as to when he contracted the disease, the presumption is that he contracted it after the effectivity of PD No. 626. Therefore, the ECC did not err in applying PD No. 626 as the governing law. The case of Caparas vs. WCC, et al., cited by the petitioner, was distinguished as it involved a claimant who contracted the disease prior to the effectivity of PD No. 626, thus falling under the old Workmen's Compensation Act.
Main Doctrine
Under Presidential Decree No. 626, for an illness to be compensable, it must be an occupational disease listed by the Commission, or any illness caused by employment, subject to proof by the employee that the risk of contracting the same was increased by working conditions. The burden of proof rests upon the claimant.