G.R. No. L-50941 March 28, 1983
Bayani V. Segismundo, petitioner, vs. Government Service Insurance System (Philippine National Railways), respondent.

FACTS

Petitioner Bayani V. Segismundo served the Philippine National Railways from 1931 until his disability retirement on April 1, 1977, having risen to the position of Chief Train Dispatcher. His duties involved extensive overtime, frequent night shifts from midnight to 8:00 A.M., and emergency work during typhoons, often requiring him to stay awake for extended periods to manage train movements and restoration efforts. After nearly twelve years of such demanding work, particularly during night shifts, he observed a deterioration in his eyesight. He was diagnosed with “glaucoma, narrow angle, bilateral” by his physician.
Segismundo filed a claim for employee’s compensation benefits, which was denied by respondent GSIS. The GSIS ruled that glaucoma was not an occupational disease, being common in middle to advanced age and attributable to factors like arteriosclerosis and heredity, and was not causally related to his work duties. The Employees’ Compensation Commission affirmed this denial, prompting this petition for review.

ISSUE

Whether petitioner’s claim for compensation benefits due to glaucoma is compensable under the applicable law.

RULING

Yes, the claim is compensable. The Supreme Court reversed the decision of the Employees’ Compensation Commission. The pivotal legal determination was the applicable law governing the onset of the illness. The Court found that the illness must have supervened in the course of his employment prior to January 1, 1975, the effectivity date of the new Labor Code (Presidential Decree No. 626). Consequently, the governing law is the old Workmen’s Compensation Act.
Under the Workmen’s Compensation Act, there exists a statutory presumption that a claim is compensable if the illness arose in the course of employment. This presumption places the burden on the employer to disprove work-connection by substantial evidence. In this case, the respondent employer failed to present any evidence to rebut this presumption. Therefore, the presumption of compensability becomes conclusive.
The Court emphasized that the demanding nature of petitioner’s work, especially the prolonged night shifts and stressful emergency duties, were precipitative factors to his glaucoma. Having served the government for over forty years, the denial of his rightful compensation would contravene the social justice objectives of the Workmen’s Compensation Act. The respondent Philippine National Railways was ordered to pay income benefits, reimburse medical expenses, and pay attorney’s fees.