GR 173049; (May, 2009) (Digest)
G.R. No. 173049 ; May 21, 2009
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), Petitioner, vs. TERESITA S. DE GUZMAN, Respondent.
FACTS
Respondent Teresita S. De Guzman, a Public Attorney III, filed a claim with the GSIS for reimbursement of medical expenses incurred for a cataract extraction procedure. She argued her ailment was work-related, having developed from decades of reading voluminous legal materials. The GSIS denied the claim, stating cataract is associated with aging, diabetes, or trauma, not reading, and noted respondent’s pre-existing diabetes mellitus. The Employees’ Compensation Commission (ECC) affirmed the denial, finding cataract not listed as an occupational disease and that her diabetes was a major causative factor.
ISSUE
Whether respondent’s cataract is compensable under Presidential Decree No. 626, as amended (the Employees’ Compensation Law), despite not being a listed occupational disease and despite the presence of a pre-existing condition (diabetes).
RULING
Yes, the cataract is compensable. For a non-listed illness to be compensable, the claimant must prove that the risk of contracting the disease was increased by the working conditions. The Court found that respondent successfully provided substantial evidence demonstrating this increased risk. Her detailed explanation of how her duties required prolonged and intensive reading of legal documents, which strained her eyes, established a reasonable connection between her work and the development of the cataract.
The Court clarified that the presence of a pre-existing disease like diabetes does not automatically disqualify a claim. The law requires only that the working conditions contributed to the development or aggravation of the ailment. Here, respondent’s work as a lawyer, involving significant visual strain, increased her risk of developing cataract alongside her diabetic condition. Furthermore, as social legislation, the implementing rules mandate a liberal interpretation in favor of the employee, with all doubts resolved for the claimant’s benefit. Thus, the Court of Appeals correctly reversed the ECC’s decision.