De Guia v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Jose De Guia, employed by the Bureau of Internal Revenue from 1956 until his retirement in 1988, experienced vision loss in 1982. An eye specialist diagnosed his condition as "Proliferative Diabetic Retinopathy with Vitreous Hemorrhage," attributing it to "continuous visual insult in the pursuit for his duties." Petitioner underwent laser photo-coagulation and panretinal photo-coagulation. Procedural History: Petitioner filed a claim for compensation benefits under Pres. Decree No. 626. The Government Service Insurance System (GSIS) denied the claim, stating that diabetes mellitus is not an occupational disease and that the nature of his work did not increase the risk of contracting his eye ailment. The Employees' Compensation Commission (ECC) affirmed the GSIS decision, finding no causal relation between the ailment and petitioner's employment. The Petition: Petitioner sought review, arguing that the stresses of his work as a Revenue Examiner predisposed him to diabetes, citing Millora v. Employees' Compensation Commission. He claimed his visual impairment was a complication of his work.
Issue(s)
Whether petitioner's ailment, "Proliferative Diabetic Retinopathy with Vitreous Hemorrhage," is compensable under Pres. Decree No. 626, considering the nature of the ailment and the burden of proof. Whether the risk of contracting petitioner's ailment was increased by his working conditions, considering the pre-existing condition of diabetes and the lack of causal relation to employment.
Ruling
The petition is denied, and the judgment of the Employees' Compensation Commission is affirmed.
Ratio Decidendi
On whether petitioner's ailment is compensable: The Court reiterated that for an ailment to be compensable, it must be an occupational disease or proven to have its risk increased by working conditions. Petitioner's "diabetic retinopathy" and its underlying cause, "diabetes mellitus," are not listed as occupational diseases in the Rules on Employees' Compensation. Therefore, petitioner bore the burden of proving that his working conditions increased the risk of contracting these ailments. The Court found that petitioner failed to discharge this burden of proof. The medical certificate, while suggesting "visual insult" from duties, also noted "complications," and the diagnosis of "diabetic retinopathy" specifically pointed to the underlying diabetic condition. On whether the risk of contracting the ailment was increased by working conditions: The Court found no causal relation between petitioner's basic illness, "diabetes mellitus," and its complication, "diabetic retinopathy," with his employment and working conditions. The Court noted that "diabetes mellitus" is a metabolic and familial disease, with genetic susceptibility, obesity, or old age as predisposing factors. Even if petitioner was not predisposed by heredity, he did not show he was not predisposed due to old age or obesity. The Court emphasized that the complication, "diabetic retinopathy," could have set in irrespective of his working conditions, as it is a known complication of diabetes. The Court distinguished the present case from Millora, where the claimant's predisposition to diabetes was not established, unlike in this case where the petitioner had been suffering from diabetes for twenty-five years, predating his employment as a Revenue Examiner.
Main Doctrine
For an ailment to be compensable under the Labor Code, it must either be an occupational disease or be proven that the risk of contracting the disease is increased by the working conditions. A complication of an underlying disease, which is not work-related, is not compensable if the underlying disease itself is not work-related and the risk of contracting the complication was not increased by the working conditions.