Meris v. Employees' Compensation Commission
REITERATIONFacts
1. The Antecedents: Mauro G. Meris, a former Deputy and Branch Clerk of Court from 1958 to 1979, received retirement benefits and temporary total disability benefits for hypertensive cardio vascular disease with myocardial infarction. He was awarded a gratuity of P33,231.89 and a monthly pension of P645.64, along with disability benefits totaling P60.00 and P4,199.34 for permanent partial disability. 2. Procedural History: The petitioner's claims were initially processed by the Government Service Insurance System (GSIS). The GSIS denied his request to convert his permanent partial disability to permanent total disability and to grant additional compensation for cataract. The Employees' Compensation Commission affirmed the GSIS's decision after reviewing the evidence. 3. The Petition: The petitioner seeks reversal of the Employees' Compensation Commission's decision through a petition for review on certiorari. He argues that his disability should be classified as permanent total and that he is entitled to additional compensation for his cataract. The Supreme Court, however, found that the conclusions of the lower bodies were factual and not subject to review, and no compelling evidence or argument was presented to warrant a reversal.
Issue(s)
Whether the petitioner's disability should be classified as permanent total instead of permanent partial. Whether the petitioner is entitled to additional compensation for his cataract.
Ruling
The petition for review on certiorari was denied, and the Decision of the respondent Commission was affirmed. No pronouncement as to costs.
Ratio Decidendi
On the classification of disability: The Court affirmed the findings of both the GSIS and the ECC that the petitioner's disability was permanent partial, not permanent total. These conclusions were based on the evidence submitted by the petitioner, including the testimony of his attending physician, and were considered factual in nature. As factual findings are generally not subject to review by the Supreme Court in a petition for certiorari, and no cogent evidence or argument was presented to warrant a reversal, the classification of permanent partial disability was upheld. The benefits awarded were consistent with this classification. On the compensability of cataract: The Court also affirmed the ECC's decision that the petitioner's eye ailment, characterized as senile cataract, was not compensable. The basis for this determination was that old age was the predisposing factor for the cataract. Furthermore, the affliction was not found to be attributable to any excessive strain on the petitioner's eyes resulting from the nature of his work. Therefore, it did not meet the criteria for compensation under the relevant laws or policies.
Main Doctrine
The Supreme Court affirmed the decision of the Employees' Compensation Commission which denied the petitioner's claim for conversion of his disability from permanent partial to permanent total, and for additional compensation for cataract, holding that the disability was permanent partial and the cataract was not compensable as it was due to old age and not attributable to work strain.