G.R. No. L-46692. April 28, 1980.
FELICITACION A. GUILLEN, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, REPUBLIC OF THE PHILIPPINES (Department of Education and Culture, Bureau of Public Schools, Cagayan I), respondents.

FACTS

Petitioner Felicitacion A. Guillen was a public school teacher from November 8, 1937, until her retirement on March 25, 1974. On August 13, 1974, she filed a claim for disability benefits with the Workmen’s Compensation Section, alleging her hypertension, heart disease, and rheumatism were contracted or aggravated by the stress and conditions of her employment. The claim underwent a procedural journey, initially dismissed, reinstated, and then dismissed again for her failure to appear at a hearing. Upon her motion for reconsideration, explaining her absence due to illness and a failed telegram, the hearing was reset. During the subsequent hearing, she presented evidence, including her service record, physician’s report, and medical receipts, while the respondent employer presented none. The referee awarded her disability compensation and medical reimbursement.
The respondent employer, through the Solicitor General, moved for reconsideration before the Workmen’s Compensation Commission (WCC), arguing prescription, lack of causal relation, and inapplicability of aggravation. The WCC reversed the referee’s award, dismissing the claim. The WCC ruled that the claim, having been filed after the effectivity of the New Labor Code (Presidential Decree No. 442), was no longer cognizable under the old Workmen’s Compensation Act. It held that the new Code had repealed the old Act, and claims filed after its effectivity, even for illnesses contracted earlier, must be prosecuted under the new system.

ISSUE

Whether the Workmen’s Compensation Commission erred in dismissing the claim based on the jurisdictional argument that the New Labor Code repealed the Workmen’s Compensation Act for claims filed after its effectivity.

RULING

Yes, the Supreme Court reversed the WCC’s decision. The Court held that the governing law for a compensation claim is the statute in force at the time of the claimant’s illness or disability, not the law at the time of filing the claim. Since petitioner’s illness was contracted and her disability occurred during her employment, which ended in March 1974—before the New Labor Code took effect on January 1, 1975—the applicable law was the Workmen’s Compensation Act. The cause of action vested under the old law, and its repeal did not extinguish claims that had already accrued. Furthermore, the Court applied the presumption of compensability under the old Act. The illness having arisen in the course of employment, it was presumed work-related. The respondent employer failed to present substantial evidence to rebut this presumption. The Court also found the petition for review was timely filed, as the records did not conclusively prove petitioner received the WCC decision. Thus, the award for disability compensation and medical expenses was reinstated.