Aquino v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Izola L. Aquino, a public school teacher with 32 years of service, was diagnosed with Acute Myocardial Infarction in 1980 and suffered another attack in 1985, leading to her retirement at age 60 due to her heart ailment. The Government Service Insurance System (GSIS) initially awarded her temporary disability benefits and permanent partial disability benefits for 19 months. Procedural History: Following the GSIS's denial of her request to convert her benefits from permanent partial to permanent total disability, Aquino appealed to the Employees' Compensation Commission (ECC). The ECC affirmed the GSIS's decision, leading Aquino to file this petition for review. The Petition: The petitioner seeks to modify or set aside the decision of the ECC, arguing that her ailment should be classified as permanent total disability rather than permanent partial disability. She contends that being forced to retire due to her illness renders her unable to perform gainful occupation, aligning with the criteria for permanent total disability as established in prior jurisprudence and the Amended Rules on Employees' Compensation.
Issue(s)
Whether the petitioner's ailment, which forced her early retirement, entitles her to permanent total disability benefits instead of permanent partial disability benefits.
Ruling
The Supreme Court set aside the decision of the Employees' Compensation Commission and ordered the GSIS to pay the petitioner permanent total disability benefits and to reimburse her medical and hospital expenses.
Ratio Decidendi
On the issue of permanent total vs. permanent partial disability: The Court found the case similar to Gonzaga v. Employees' Compensation Commission, where a teacher was forced to retire due to her ailments and was deemed entitled to permanent total disability benefits. The Court reiterated that when an employee is forced to retire from work as a direct consequence of an illness contracted in the course of employment, and is rendered incapable of further pursuing her usual job, she should be compensated for permanent total disability. The fact that an employee is forced to retire ahead of schedule due to a weakened bodily condition from illness, rather than old age, supports the claim for compensation for inability to work. Furthermore, the approval of optional retirement for being physically incapable to render sound and efficient service under CA 186, as amended, also indicates a disability. The Court noted that the GSIS awarded permanent partial disability benefits for 19 months, but Section 2, Rule 7 of the Amended Rules on Employees' Compensation defines permanent total disability as an inability to perform any gainful occupation for a continuous period exceeding 120 days. Therefore, the public respondent erred in denying the petitioner's claim for permanent total disability benefits.
Main Doctrine
An employee forced to retire due to an illness contracted in the course of employment, rendering them incapable of performing their usual job, is entitled to permanent total disability benefits, not merely permanent partial disability benefits.