GR 50142; (August, 1981) (Digest)
G.R. No. L-50142 August 17, 1981
Jose E. Barrameda, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Philippine National Bank), respondents.
FACTS
Petitioner Jose E. Barrameda, a former Branch Manager of the Philippine National Bank, retired on March 8, 1976, at age 58, due to a benign lung tumor diagnosed in June 1974. He had served for over 27 years. He filed a claim for disability income benefits under Presidential Decree No. 626, as amended. The GSIS denied the claim, reasoning his ailment was not occupational and his medical treatment occurred prior to the effectivity of PD 626 on January 1, 1975. Barrameda protested, arguing his exposure to dust from mutilated bills while working as a cashier caused his illness. The Employees’ Compensation Commission affirmed the GSIS denial, finding no proof of a causal link between his employment and the lung tumor and reiterating the inapplicability of PD 626 as his sickness was contracted in 1974.
ISSUE
Whether the petitioner is entitled to disability compensation benefits under the applicable employees’ compensation law.
RULING
Yes. The Supreme Court set aside the ECC decision and granted the claim. The legal logic proceeds from two key determinations. First, on the applicable law, the Court held that the cause of action accrued when the illness was contracted in June 1974. Therefore, the governing law is the old Workmen’s Compensation Act ( Act No. 3428 , as amended), not PD 626. Under the old Act, the presumption of compensability applies—once an illness supervenes during employment, it is presumed work-related, and the burden to rebut this presumption shifts to the employer.
Second, on compensability, the GSIS itself performed a volte-face and admitted the validity of the claim. More critically, the ECC and GSIS failed to present substantial evidence to overcome the statutory presumption of compensability under the old law. Their denial was based merely on the absence of direct proof of causation, which is insufficient to rebut the presumption. Furthermore, the Court, citing precedents like Cayaba v. WCC, ruled that an employee forced into optional retirement due to a disabling work-connected illness is entitled to compensation for the income lost during the remaining years until compulsory retirement. Consequently, the Court ordered the GSIS to pay Barrameda P6,000 as disability benefits, P600 as attorney’s fees, and to reimburse his medical expenses.