G.R. No. 105854. August 26, 1999.
ANIANO E. IJARES, petitioner, vs. THE COURT OF APPEALS, EMPLOYEES COMPENSATION COMMISSION AND GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.

FACTS

Petitioner Aniano E. Ijares was a government employee, working as a Researcher at the Institute of National Language of the DECS since March 16, 1955. In 1983, he was diagnosed with PTB Minimal and Emphysema. From May 1 to 31, 1985, he went on sick leave due to chronic emphysema and then availed of early retirement on June 1, 1985, at age 60, after 30 years of service. In 1988, he was confined at the Philippine General Hospital for Chronic Obstructive Pulmonary Diseases, Emphysema, PTB class IV and S/P Pneumothorax, Right. A Pulmonary Function Test indicated Severe Obstructive Ventilatory Pattern, and Dr. Leon James Young found him to be suffering from Permanent Total Disability. On January 5, 1989, he filed a claim for Permanent Total Disability benefits with the GSIS under P.D. No. 626. The GSIS granted him only Permanent Partial Disability compensation for 19 months (June 1, 1985 to December 31, 1986) and denied his request for the original claim, stating he was already awarded maximum benefits commensurate to his disability at retirement. The ECC affirmed the GSIS, ruling that his 1988 confinement could not be attributed to his employment as he had retired in 1985, and severance of the employee-employer relationship releases the State Insurance Fund from liability for sickness after retirement. The Court of Appeals affirmed the ECC’s decision.

ISSUE

Whether petitioner is entitled to Permanent Total Disability benefits, as opposed to the Permanent Partial Disability benefits granted, for his work-connected illness that persisted and was declared permanent and total after his retirement.

RULING

Yes. The Supreme Court granted the petition and set aside the decision of the Court of Appeals, declaring petitioner entitled to Permanent Total Disability benefits. The Court held that the petitioner’s temporary total disability lasting continuously for more than 120 days should be considered permanent total disability under Rule XI, Section 1(b) of the Amended Rules on Employees Compensation. The fact that his illness was diagnosed as permanent and total after his retirement does not negate compensability, as the illness was contracted during his employment. The Court emphasized that the law on employees’ compensation is a social legislation that must be liberally construed in favor of the employee. The severance of the employee-employer relationship does not automatically deprive a claimant of benefits for an illness that originated during employment. The possibility of future recovery or gainful employment does not justify denying a rightful claim for permanent total disability.