G.R. No. 196102 , November 26, 2014
Government Service Insurance System vs. Aurelia Y. Calumpiano

FACTS

Aurelia Y. Calumpiano was employed as a Court Stenographer at the then Court of First Instance of Samar from January 5, 1972, until her retirement on March 30, 2002. Shortly before her retirement, on March 7, 2002, she filed an application for disability retirement with the Supreme Court on account of her ailments, Hypertensive Cardiovascular Disease and Acute Angle Closure Glaucoma, supported by medical certificates from her attending ophthalmologists. The Supreme Court approved her application for disability retirement under Republic Act No. 8291 . Her disability claim was forwarded to the GSIS, which denied it on the ground that hypertension and glaucoma were not work-related. Her motion for reconsideration was likewise denied. She appealed to the Employees’ Compensation Commission (ECC), which affirmed the GSIS’s denial. The ECC held that while her duties as a stenographer were stressful and may have caused her hypertension, for it to be compensable, there must be impairment of function of body organs resulting in permanent disability, which was not shown as her ECG report indicated no end-organ damage. It also held that glaucoma could not be considered work-connected as medical science indicates it is related to intraocular pressure and there was nothing in her duties that would cause or increase her risk of contracting it. Calumpiano filed a Petition for Review with the Court of Appeals, which set aside the ECC Decision and ordered the payment of disability benefits, finding her illnesses were contracted and aggravated during her employment and were connected to the stressful nature of her work under the “increased risk theory.” The CA denied GSIS’s motion for reconsideration.

ISSUE

1. Whether the Court of Appeals erred in finding that respondent’s diseases (hypertension and glaucoma) are compensable under the increased risk theory.
2. Whether the Court of Appeals erred in reversing the findings of facts of the ECC.

RULING

The Supreme Court denied the Petition, affirming the CA’s decision. The Court held that while essential hypertension is listed as an occupational disease under the implementing rules of PD 626, it is a qualified occupational disease, compensable only if it causes impairment of function of body organs like kidneys, heart, eyes, and brain, resulting in permanent disability, supported by specific documents. The degree of proof required is substantial evidence, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion; probability, not ultimate certainty, is the test. The Court found that Calumpiano’s medical reports and drug prescriptions from her attending physicians sufficiently supported her claim, and neither GSIS nor the ECC convincingly denied their genuineness. Furthermore, the Court noted that medical literature establishes a link between hypertension and glaucoma, indicating that hypertension can contribute to the development or progression of glaucoma. Given that her hypertension was likely work-related due to the stressful nature of her duties as a court stenographer, and considering the established medical link, her glaucoma could also be deemed work-connected. The Court emphasized that employees’ compensation laws are social legislation, and any doubt in their interpretation must be resolved in favor of the employee. The CA did not err in reversing the ECC’s findings, as it is not precluded from making its own assessment, especially when based on substantial evidence supporting compensability.