G.R. No. L-46634. January 28, 1980.
FLORENCIO BALATERO, petitioner, vs. EMPLOYEES COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (DEPARTMENT OF EDUCATION AND CULTURE), respondents.

FACTS

Petitioner Florencio Balatero was a public school teacher and District Adult and Community Education Coordinator for the Iligan City North Central School. His duties extended beyond the classroom, requiring him to travel to various communities to supervise projects. His medical history shows he experienced symptoms of dizziness, headache, and hearing loss as early as 1972. Following a high fever and severe cold in September 1973, he suffered total hearing impairment. Subsequent examinations revealed a perforated tympanic membrane and a final diagnosis of “Hypertension with Impairment of Hearing.” He retired on May 9, 1975, and later filed a claim for compensation benefits under the new Employees’ Compensation Program (P.D. No. 626).
The GSIS denied the claim, finding no direct causal link between his duties and his ailment, and stated that mere aggravation was no longer compensable under the new law. The Employees’ Compensation Commission affirmed the denial, citing lack of evidence connecting the illness to his employment and suggesting it was age-related presbycusis. The Commission also ruled it lacked jurisdiction because the illness’s onset in 1972 preceded the January 1, 1975 effectivity date of the new program.

ISSUE

The primary issue is whether petitioner’s claim for compensation benefits for his hypertension and hearing loss is governed by the old Workmen’s Compensation Act or the new Employees’ Compensation Program, and consequently, whether his ailments are compensable.

RULING

The Supreme Court ruled in favor of the petitioner, setting aside the ECC decision. The legal logic is anchored on the principle of non-retroactivity and vested rights. The Court held that the governing law is the Workmen’s Compensation Act, not P.D. No. 626, because the cause of action accrued in 1972 when his symptoms first manifested, while the old law was still in force. Rights which vested under a prior statute survive its repeal.
Under the Workmen’s Compensation Act, the supervenience of an illness during employment gives rise to a rebuttable presumption that the claim is compensable. The burden shifts to the employer to disprove this connection. Here, it was undisputed that Balatero’s ailments supervened in the course of his employment, and the respondents even admitted the work could have aggravated his condition. This admission, coupled with the strenuous nature of his fieldwork, which exposed him to the elements and led to the fever preceding his deafness, satisfied the condition for compensability under Section 2 of the old Act, which covered illnesses “aggravated by or the result of the nature of such employment.” The Court also noted that the filing of the claim with the GSIS, though technically incorrect under the old law’s procedure, did not prejudice the claim, and any interpretative doubts must be resolved in favor of the laborer. The GSIS was ordered to pay disability benefits, reimburse medical expenses, and cover attorney’s fees.