G.R. No. 83232; July 4, 1991
Trinidad M. Villas, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Western Police District Integrated National Police), respondents.

FACTS

Petitioner Trinidad M. Villas, a police officer, sustained a head injury from a rock during a violent demonstration in 1970. This incident led to a series of medical issues, including severe headaches, fainting spells, and seizures, diagnosed as a generalized motor seizure in 1972. He underwent multiple hospital treatments and operations over the following years. On March 17, 1981, after a prolonged hospitalization at Camp Panopio, he was discharged with a recommendation for disability retirement, which he effected on October 23, 1981.
Villas filed a claim for compensation benefits on August 16, 1984. The GSIS initially granted a sum of P13,920, representing benefits for a period deemed to have started from April 26, 1977, but later denied further payments, asserting he had received the maximum P12,000 benefit allowed under the law applicable to contingencies before May 1, 1978. The ECC affirmed this denial. Villas appealed, contending his permanent total disability should be deemed to have occurred only in 1981, upon the definitive medical recommendation for retirement, thereby making the more favorable amended provisions of PD 626 (which removed the P12,000 cap) applicable.

ISSUE

The core issue is the determination of the date when the petitioner’s permanent total disability accrued for the purpose of computing his compensation benefits under PD 626, as amended.

RULING

The Supreme Court ruled in favor of Villas. The Court held that the accrual of the cause of action for disability benefits is reckoned from the time the employee becomes incapacitated to perform his regular work, not merely from the initial onset or diagnosis of the illness. Following the precedent in Vda. de Torbela v. ECC, disability is deemed to have occurred when the employee is medically pronounced unfit for work.
In this case, Villas was pronounced permanently disabled only upon his discharge from Camp Panopio Hospital on March 17, 1981, with an explicit retirement recommendation. This date falls after the amendment of PD 626 by PD 1368, which removed the P12,000 maximum benefit limit. Consequently, the amended law, not the old version with its monetary cap, governs his claim. His subsequent claim was filed within the prescriptive period. The Court emphasized that any doubt in the interpretation of social legislation should be resolved in favor of the worker, especially a dedicated public servant disabled in line of duty. The decision of the ECC was reversed, and the GSIS was ordered to pay Villas lifetime permanent total disability benefits commencing from his retirement date.