Hatta Hataie v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner, Mally A. Hatta Hataie, served in government from September 1958 until his retirement as Collector of Customs on June 1, 1988. In 1985, prior to retirement, he experienced blurring of vision, eye pain, and photophobia, diagnosed as neovascular glaucoma. Despite four unsuccessful eye operations, his vision deteriorated. Procedural History: Petitioner filed a disability benefit claim with the Government Service Insurance System (GSIS) under Presidential Decree No. 626. The GSIS denied the claim on June 10, 1988. The Employees' Compensation Commission (ECC) affirmed the GSIS denial on February 14, 1990, concluding that neovascular glaucoma is not work-related and there was no proof of increased risk due to his occupation. The Petition: This petition for review on certiorari challenges the ECC's decision. The original petitioner passed away during the pendency of the case, and his estate's executor, Edwin O. Hatta, was substituted.
Issue(s)
Whether neovascular glaucoma is a compensable illness under Presidential Decree No. 626. Whether the petitioner's work as Collector of Customs increased the risk of contracting neovascular glaucoma.
Ruling
The petition is denied, and the decision of the respondent Employees' Compensation Commission is affirmed.
Ratio Decidendi
On the compensability of neovascular glaucoma: The Court affirmed the ECC's ruling that neovascular glaucoma is not compensable. To be entitled to disability benefits under Presidential Decree No. 626, an illness must either be listed as an occupational disease, or the employee must prove that the risk of contracting the illness is increased by working conditions. Neovascular glaucoma is a secondary glaucoma, and its initial causes are not known, with predisposing factors including advanced age, arteriosclerosis, vasomotor instability, hyperopia, and heredity. The Court found no proof that the petitioner's ailment was caused or even preceded by another eye disease or injury, nor that severe eye strain from reading increased the risk of contracting neovascular glaucoma. The Court emphasized that the underlying cause of glaucoma is chiefly due to the structure of the eye itself and is considered a non-work-related factor. On whether the petitioner's work increased the risk of contracting the illness: The Court found no relation between the petitioner's work as Collector of Customs and the illness of neovascular glaucoma. While the petitioner alleged that his work involved reading voluminous documents, causing severe eye strain, this strain was not classified as a disease or injury that causes or contributes to neovascular glaucoma. The Court distinguished this case from previous rulings where glaucoma was compensated, noting that those cases applied the old Workmen's Compensation Act which presumed compensability if the ailment occurred or was aggravated during employment. Under PD 626, the burden of proof is on the claimant to establish a positive proposition that the risk of contracting the disease is increased by working conditions. The petitioner failed to establish this causal relationship or increased risk.
Main Doctrine
To be entitled to disability benefits under the Employees' Compensation Law (PD 626), an employee must prove that the illness arose out of or in the course of employment, or is an occupational disease, or that the risk of contracting the illness is increased by working conditions. Neovascular glaucoma, being a secondary glaucoma with unknown initial causes and predisposing factors such as advanced age, arteriosclerosis, and heredity, is not compensable unless a direct causal relationship to employment or an increased risk due to working conditions is established.