GR L 46443; (June, 1988) (Digest)
G.R. No. L-46443 June 28, 1988
NONATO ROSALES, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION, GOVERNMENT SERVICE INSURANCE SYSTEM and The DEVELOPMENT BANK OF THE PHILIPPINES, respondents.
FACTS
Petitioner Nonato Rosales was an employee of the Development Bank of the Philippines, having held various clerical positions. He was diagnosed with Rheumatoid Arthritis and confined in April 1976. Following his disability, he retired on July 31, 1976. Subsequently, on August 12, 1976, he filed a claim for employees’ compensation benefits under Presidential Decree No. 626 with the Government Service Insurance System (GSIS). The GSIS denied his claim, a decision which was affirmed by the Employees’ Compensation Commission (ECC) on appeal. The ECC ruled that Rheumatoid Arthritis is not a listed occupational disease and that Rosales failed to prove that the risk of contracting it was increased by his working conditions.
ISSUE
Whether the Employees’ Compensation Commission committed grave abuse of discretion in denying Rosales’s claim for compensation benefits under P.D. No. 626.
RULING
The Supreme Court denied the petition, finding no merit in Rosales’s claims. The legal logic hinges on the applicable law governing compensation claims. The Court emphasized that the governing law is determined by the date the illness was contracted. P.D. No. 626, which took effect on January 1, 1975, applies to ailments occurring after that date. Under this law, for an illness to be compensable, it must either be a listed occupational disease or the employee must prove that the risk of contracting it was increased by the working conditions. Rosales filed his claim explicitly under P.D. No. 626, and his petition did not allege when he contracted Rheumatoid Arthritis. Consequently, the presumption was that the disease was contracted after the law’s effectivity, making P.D. No. 626 the proper governing statute. The ECC correctly applied this law in finding that Rheumatoid Arthritis is not a listed occupational disease and that Rosales failed to provide substantial evidence linking his condition to his employment. The Court also distinguished the cited case of Caparas vs. WCC, as that ruling was based on the old Workmen’s Compensation Act, which applied to illnesses contracted before P.D. No. 626. Therefore, the ECC’s decision was in accordance with law and not tainted with grave abuse of discretion.