GR 48488; (April, 1980) (Digest)

G.R. No. L-48488. April 25, 1980.
Gloria D. Menez, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Department of Education & Culture), respondents.

FACTS

Petitioner Gloria D. Menez was a public school teacher for 32 years, assigned at Raja Soliman High School in Manila. She retired on August 31, 1975, under a disability retirement plan at age 54, due to rheumatoid arthritis and pneumonitis. Her school was situated near a polluted creek, a market, squatter areas, and commercial establishments. She filed a claim for disability benefits under Presidential Decree No. 626, as amended, with the Government Service Insurance System (GSIS) in October 1976.
The GSIS denied her claim, asserting her ailments were not occupational diseases listed under the law and were not causally related to her teaching duties. The GSIS found the ailments traceable to non-work factors. The Employees’ Compensation Commission (ECC) affirmed the denial, stating the employment had nothing to do with the development of her illnesses and that the ailments were not listed as occupational diseases for her employment.

ISSUE

Whether petitioner’s ailments, rheumatoid arthritis and pneumonitis, are compensable under the employees’ compensation law despite not being listed as occupational diseases.

RULING

Yes. The Supreme Court set aside the ECC decision and granted the claim. The legal framework under P.D. No. 626 requires that for a sickness to be compensable, it must either be a listed occupational disease or an illness caused by employment, with the employee proving that the risk of contracting it was increased by working conditions. The Court found that while rheumatoid arthritis and pneumonitis are not listed occupational diseases, the petitioner successfully demonstrated that her working conditions increased the risk of contracting them.
The Court applied the legal principle of aggravation. It held that the nature of a teacher’s work—exposure to varying temperatures from afternoon and night shifts, exposure to pollution from the surrounding environment, and constant exposure to students with respiratory infections—increased the risk of developing or aggravating pneumonitis. For rheumatoid arthritis, the Court noted that the physical and nervous strain inherent in teaching, recognized by the Magna Charta for Public School Teachers, constituted a working condition that could precipitate or aggravate such an ailment. The Court emphasized that the law must be construed liberally in favor of the employee. Since her disabilities forced her retirement, a causal link between her working conditions and the aggravation of her illnesses was established, warranting compensation. The Ministry of Education and Culture was ordered to pay disability benefits and reimburse medical expenses.