GR 46802; (April, 1980) (Digest)
G.R. No. L-46802. April 28, 1980.
RUSTICO L. CENABRE, petitioner, vs. EMPLOYEE’S COMPENSATION COMMISSION, respondent.
FACTS
Petitioner Rustico Cenabre was a public school teacher who served from 1950 until his disability retirement in 1976. His medical history from 1965 to 1975 documented recurrent ailments, including peptic ulcer and acute gastritis, necessitating multiple hospital confinements. His attending physician ultimately ordered complete rest. Due to his worsening condition, he applied for disability retirement in October 1975. Subsequently, he filed a claim for disability benefits under P.D. No. 626 with the Government Service Insurance System (GSIS). The GSIS denied the claim, asserting his ailments were not occupational diseases and that he failed to prove a causal link between his illnesses and his employment. This denial was affirmed by the respondent Employees’ Compensation Commission, which emphasized the petitioner’s inability to demonstrate that his working conditions increased the risk of contracting his diseases.
ISSUE
The primary issue is whether the petitioner’s claim for disability compensation, stemming from illnesses that manifested and caused disability beginning in 1965, is governed by the Workmen’s Compensation Act (the old law) or by the provisions of P.D. No. 626 (the new law).
RULING
The Supreme Court ruled in favor of the petitioner, setting aside the decision of the Employees’ Compensation Commission. The legal logic is anchored on the principle that the law in effect at the time a cause of action accrues governs its prosecution. The Court found that the petitioner’s cause of action for disability benefits accrued as early as April 1965, when his illnesses first prevented him from working for more than three days, thereby entitling him to benefits under the then-governing Workmen’s Compensation Act. Since the right accrued under the old law, it survived the subsequent repeal of that statute.
Under the Workmen’s Compensation Act, the petitioner’s illnesses enjoyed a rebuttable presumption of compensability, meaning they were presumed to have arisen out of or were aggravated by his employment. The burden to disprove this presumption shifted to the employer. The Court noted the employer’s failure to comply with mandatory statutory duties, such as filing a timely notice of illness or controverting the claim within the prescribed period for the initial and subsequent disabilities starting in 1965. This failure constituted a waiver of non-jurisdictional defenses and rendered the presumption of compensability conclusive. The Court also found that the prescriptive period for filing the claim did not commence until his actual retirement in 1976, when he became permanently incapacitated. Consequently, the claim was timely and compensable under the old law’s more favorable provisions, which align with the social justice objectives of the Constitution and protective statutes for public school teachers. The GSIS was ordered to pay disability compensation and reimburse medical expenses.