GR 45910; (April, 1980) (Digest)
G.R. No. L-45910 April 28, 1980
Eligio P. Mirasol, petitioner, vs. Employee’s Compensation Commission and Government Service Insurance System (Department of Education and Culture), respondents.
FACTS
Eligio P. Mirasol served as a public school teacher and coordinator in Libmanan, Camarines Sur, from 1945 until his retirement in 1976. His later assignments, including District Food Production Coordinator and District Vocational Coordinator, required him to conduct monthly visits to forty-eight barrio schools. Eighteen of these schools were located in mountainous areas inaccessible by road, necessitating travel on foot through muddy rice fields and slippery mountain trails, often under harsh weather conditions. During these duties, he suffered multiple falls.
In August 1973, Mirasol first experienced symptoms of malignant hypertension and rheumatoid arthritis in both knees. These ailments persisted, requiring continuous medical treatment and ultimately forcing his retirement. He subsequently filed a claim for disability benefits under the Employees’ Compensation Act (P.D. No. 626) with the Government Service Insurance System (GSIS).
ISSUE
Whether the ailments of hypertension and rheumatoid arthritis are compensable as occupational diseases, having been caused or aggravated by the conditions of Mirasol’s employment.
RULING
Yes. The Supreme Court reversed the decisions of the GSIS and the Employee’s Compensation Commission (ECC), which had denied the claim on the ground that the ailments were not listed as occupational diseases. The Court applied the legal principle that for a sickness to be compensable, the claimant must show that the risk of contracting the disease was increased by the working conditions.
The Court found substantial evidence that Mirasol’s specific duties directly contributed to his ailments. The rigorous monthly hikes through difficult terrain and exposure to the elements, compounded by his repeated falls, constituted working conditions that increased the risk of developing his conditions. This established a causal link between his employment and the ailments, satisfying the requirement for compensability under the law. Consequently, the Court awarded Mirasol permanent total disability benefits, reimbursement for medical expenses, and attorney’s fees. The dissent argued that the ailments were not occupational and their etiology was not definitively work-related, but the majority emphasized the factual circumstances of increased risk due to employment duties.