Domingo Vicente v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Domingo Vicente, a nursing attendant at the Veterans Memorial Medical Center, applied for optional retirement effective August 16, 1981, at age 45, citing physical disability. He also filed a claim for income benefits under PD No. 626, as amended, supported by a Physician's Certification diagnosing him with Osteoarthritis, multiple; Hypertensive Cardiovascular Disease; Cardiomegaly; and Left Ventricular Hypertrophy, classifying him under "permanent total disability." The GSIS granted him permanent partial disability (PPD) compensation for nineteen months. Procedural History: Petitioner requested reconsideration from the GSIS, which granted an additional four months of benefits. Unsatisfied, he insisted on permanent total disability compensation. The GSIS denied his request on June 30, 1987. His case was elevated to the Employees' Compensation Commission (ECC). While awaiting the ECC's decision, he was confined for "CVA probably thrombosis of the left middle cerebral artery." On August 24, 1988, the ECC affirmed the GSIS ruling, classifying his disability as permanent partial. The Petition: Petitioner assails the ECC decision, maintaining that his disability is permanent total, not permanent partial. He relies on his attending physicians' certifications and argues that his subsequent confinement for CVA was a direct result of his pre-existing ailments. The respondent Commission argued that the attending physician's findings are not binding and that the GSIS medical experts exclusively determine the degree of disability.
Issue(s)
Whether petitioner Domingo Vicente suffers from permanent total disability or permanent partial disability. Whether the findings of the petitioner's attending physician are binding on the GSIS and the ECC.
Ruling
The Supreme Court ruled in favor of the petitioner, setting aside the decision of the Employees' Compensation Commission and declaring petitioner Domingo Vicente as suffering from permanent total disability. The ECC was ordered to award the petitioner the benefits corresponding to his permanent total disability.
Ratio Decidendi
On the classification of disability: The Court reiterated that permanent total disability means the employee is unable to perform any gainful occupation for a continuous period exceeding 120 days. The approval of petitioner's optional retirement at age 45, after over 25 years of service, due to physical incapacity, strongly indicated that he was no longer fit to continue in his employment. Furthermore, the categorical certification by the employer's physicians classifying him under permanent total disability is given credence, as physicians are not expected to issue false certifications. The fact that he was granted benefits equivalent to twenty-three months further supports the conclusion that he was unable to perform any gainful occupation for a continuous period exceeding 120 days, which is the definition of permanent total disability under Section 2(b), Rule VII of the Amended Rules on Employees' Compensability. The Court emphasized that the law, particularly concerning social security, requires construction of utmost liberality in favor of beneficiaries. On the binding nature of physician's certifications: While the respondent Commission argued that the attending physician's findings are not binding, the Supreme Court has consistently given credence to such certifications, especially when issued by the employer's physicians. The Court noted that physicians are aware of the serious consequences of their statements and would not issue certifications indiscriminately. The certification from the petitioner's attending doctor at the Veterans Memorial Medical Center, diagnosing him with multiple ailments and classifying him as under permanent total disability, was a significant factor in the Court's determination.
Main Doctrine
The determination of whether an employee suffers from permanent total disability hinges on the inability to perform any gainful occupation for a continuous period exceeding 120 days, and the approval of optional retirement due to physical incapacity is a strong indicator of such disability.