GR 132648; (March, 1999) (Digest)
G.R. No. 132648 March 4, 1999
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), petitioner, vs. COURT OF APPEALS and ROMEO S. BELLA, respondents.
FACTS
Romeo S. Bella, a government employee, retired in 1986 but was re-employed in 1987. He suffered from Acute Myocardial Infarction and Ischemic Cardiomyopathy, leading to hospital confinements. The GSIS initially granted him Permanent Partial Disability (PPD) benefits. Bella later requested conversion to Permanent Total Disability (PTD) benefits, supported by medical certifications stating his inability to engage in any gainful occupation for over 120 days due to his ailments. The GSIS denied his request, contending that his disability did not meet the criteria for PTD. The Employees Compensation Commission (ECC) affirmed the GSIS decision.
ISSUE
Whether Romeo S. Bella is entitled to Permanent Total Disability benefits under P.D. 626, as amended.
RULING
Yes. The Supreme Court affirmed the Court of Appeals’ decision granting PTD benefits. The legal logic hinges on the statutory definition and jurisprudential interpretation of permanent total disability. Under the implementing rules, a disability is total and permanent if it prevents the employee from performing any gainful occupation for a continuous period exceeding 120 days. The Court, citing Vicente vs. Employees Compensation Commission, clarified that the test is the employee’s capacity to continue performing his work. It is not the mere loss of a specific bodily function but the incapacity to work that is decisive.
The GSIS and ECC erroneously relied solely on the Schedule of Compensation, which quantifies disability based on anatomical loss, to deny PTD benefits. The Court ruled that this schedule is not exclusive for determining PTD entitlement. Bella’s medical certifications, which the GSIS did not refute, conclusively established his inability to perform any gainful work for more than 120 days. This condition satisfies the legal standard for PTD, regardless of the prior PPD award. The law is construed liberally in favor of the worker. Therefore, Bella’s physical incapacity to work rendered him permanently and totally disabled, entitling him to the corresponding benefits.