GR 136453; (September, 2000) (Digest)
G.R. No. 136453 ; September 21, 2000
Petrita Y. Bonilla, petitioner, vs. Court of Appeals, Government Service Insurance System (GSIS) and Employees’ Compensation Commission, respondents.
FACTS
Petitioner Petrita Y. Bonilla, a long-time government employee serving as a Legislative Staff Officer V at the Senate, experienced sudden blurring of vision in her right eye in April 1995. She was diagnosed with Rhegmatogenous Retinal Detachment and underwent surgery. She filed a claim for compensation benefits under P.D. No. 626, as amended.
The GSIS denied her claim, ruling that her ailment was not a listed occupational disease and that her employment did not increase the risk of contracting it. The Employees’ Compensation Commission affirmed this denial. The Court of Appeals subsequently denied her petition, finding a lack of relevant evidence to prove her illness was work-connected.
ISSUE
Whether petitioner’s illness is work-connected or the risk of contracting it was increased by her working conditions, thereby entitling her to compensation benefits under P.D. No. 626, as amended.
RULING
The Supreme Court ruled in favor of the petitioner, reversing the decisions of the lower tribunals. The legal logic is anchored on the provisions of P.D. No. 626, which defines a compensable sickness as either a listed occupational disease or any illness caused by employment, subject to proof that the risk of contracting it is increased by working conditions.
While retinal detachment is not a listed occupational disease, compensability can still be established by showing a reasonable work connection through substantial evidence. The Court found that the petitioner presented uncontroverted evidence that she suffered from hypertension caused by stress and tension from her long tenure as a court stenographer and legislative staff officer. Medical authority recognizes hypertension as an admitted cause of retinal detachment. This established that the very nature of her ailment substantiated its work connection and the increased risk due to her employment.
The Court emphasized that the degree of proof required is merely substantial evidence, and strict rules of evidence do not apply. Probability, not absolute certainty, is the standard for compensability. The lower courts erred in requiring a higher degree of proof. Consequently, the petitioner’s illness was deemed work-connected and compensable.