GR 79009; (July, 1990) (Digest)
G.R. No. 79009 July 20, 1990
Arcadia Vistal, petitioner, vs. Employees’ Compensation Commission, Government Service Insurance System (Department of Education, Culture & Sports), respondents.
FACTS
Arcadia Vistal, an elementary school teacher from Bohol, retired on June 3, 1974. She contracted pulmonary tuberculosis, essential hypertension, and rheumatoid arthritis in 1973. On September 9, 1983, she filed a claim for disability benefits. The Government Service Insurance System (GSIS) denied her claim, asserting it only had jurisdiction over claims arising on or after January 1, 1975, under the new Employees’ Compensation Law (PD 626). The Employees’ Compensation Commission (ECC) dismissed her appeal, ruling her claim was governed by the old Workmen’s Compensation Act ( Act No. 3428 ) but had prescribed, as it was filed ten years after her cause of action accrued in 1973.
Vistal filed this petition for certiorari, arguing her claim was compensable under the Workmen’s Compensation Act. The Solicitor General, GSIS, and ECC concurred that the old law applied. However, the Solicitor General contended the claim was filed within the ten-year prescriptive period and was compensable, given the nature of her employment and her retirement due to disability.
ISSUE
Whether petitioner’s claim for disability benefits had prescribed and, if not, whether it is compensable and who is liable for payment.
RULING
The Supreme Court granted the petition. On prescription, the Court held that claims under the Workmen’s Compensation Act prescribe in ten years pursuant to Article 1144 of the Civil Code. Since Vistal’s ailments accrued in 1973 without a specific date, any doubt must be resolved in favor of the worker. Her claim filed on September 9, 1983, was thus filed within the ten-year period from the accrual of her cause of action.
On compensability, the Court ruled her ailments were compensable under the Workmen’s Compensation Act. As a teacher, her illnesses were directly caused or aggravated by her employment duties. The principle of presumption of compensability applied. Furthermore, her optional retirement at age 61 indicated physical incapacity to render efficient service, supporting the work-connection of her disabilities. Tuberculosis has been recognized as an occupational disease for teachers.
Regarding liability, the Court held that since the claim was adjudged compensable under the Workmen’s Compensation Act, the employer is primarily liable. The GSIS’s jurisdiction is limited to claims under the new law for incidents occurring on or after January 1, 1975. Consequently, the Department of Education, Culture and Sports (DECS), as her employer, was ordered to pay Vistal Six Thousand Pesos (P6,000.00) as maximum compensation, attorney’s fees, and administrative costs. The ECC decision was set aside.