Erese v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Felipe U. Erese filed a claim for disability compensation under Presidential Decree No. 626 with the GSIS for ailments including Inguinal Hernia, Error of Refraction, Central Retinopathy, and Chronic Otitis Media. The GSIS denied the claim, stating these were not occupational diseases and Erese failed to substantially prove they resulted from his occupation as a Supervising Prison Guard. Procedural History: The Employees' Compensation Commission (ECC) affirmed the GSIS's denial. Erese filed a petition for review. The Petition: Erese alleged that his duties as a prison guard, including escorting prisoners over long distances, exposure to elements, insufficient rest and sleep, and involvement in prison riots, caused or aggravated his ailments. He detailed specific incidents, such as wading through seawater during an escort duty which caused blood to come out of his ear, and being caught in a typhoon, which he claimed worsened his conditions. He was operated on for hernia and treated for his eyes and ears. He asserted that these illnesses led to his partial and total disability.
Issue(s)
Whether Erese's ailments are compensable occupational diseases under Presidential Decree No. 626. Whether Erese substantially proved that his ailments arose out of his employment. Whether the presumption of compensability under the former Workmen's Compensation Act applies to his claim.
Ruling
The Supreme Court affirmed the decision of the Employees' Compensation Commission denying Erese's claim for disability compensation.
Ratio Decidendi
On whether Erese's ailments are compensable occupational diseases under Presidential Decree No. 626: The Court held that Erese's ailments, namely Inguinal Hernia, Error of Refraction, Central Retinopathy, and Chronic Otitis Media, could not be classified as occupational diseases under PD 626. The Court provided definitions for each ailment, noting that Inguinal Hernia is caused by congenital weakness, Error of Refraction can be congenital or hereditary, Macular Retinopathy may be hereditary or due to senile/arteriosclerotic diseases, and Otitis Media is a chronic infection of the middle ear. These descriptions did not inherently link them to the specific risks of his employment as a prison guard. On whether Erese substantially proved that his ailments arose out of his employment: The Court found that Erese failed to substantially prove that his ailments arose out of his employment. For an illness to be compensable under PD 626, it must be a listed occupational disease or the employee must prove that the working conditions increased the risk of contracting it. The Court noted that the hazards of his employment were not peculiar enough to have naturally caused the defects in his eyes and ears. Regarding hernia, the Court cited the conditions for compensability established in Bonilla v. Workmen's Compensation Commission, which require the hernia to be of recent origin, accompanied by pain and tissue tearing, immediately preceded by strain, and with a subsequent protrusion. The Court opined that Erese's hernia appeared to be long-standing and not of recent origin, and that he failed to present convincing proof of a causal relationship between his work and his ailments. On whether the presumption of compensability under the former Workmen's Compensation Act applies to his claim: The Court clarified that the presumption of compensability and the rule on aggravation of illness, which favored the employee under the former Workmen's Compensation Act, were deliberately repealed and abandoned under the Employees' Compensation Act (PD 626). The Court explained that these doctrines were removed to restore a balance between employer and employee interests. Therefore, Erese could not benefit from these presumptions. Furthermore, the Court found no evidence that Erese contracted his diseases or ailments before January 1, 1975, the effectivity of the Labor Code. His first medical treatment for hernia and defects in his eyes and ears was on January 10, 1976, and his medical history was noted as "not remarkable" prior to that. The Court concluded that it would be pure conjecture to rule that his diseases accrued or were aggravated prior to January 1, 1975, and thus the claim should be governed by PD 626, which requires substantial proof.
Main Doctrine
Under Presidential Decree No. 626, for an illness to be compensable, it must be either a listed occupational disease or the employee must substantially prove that the risk of contracting the illness is increased by working conditions. The presumption of compensability and the rule on aggravation of illness under the former Workmen's Compensation Act were deliberately repealed and abandoned under the Employees' Compensation Act.