G.R. No. 83568 ; July 18, 1991
PROSPERO NAVAL, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.

FACTS

Petitioner Prospero Naval served the government from 1950 until his retirement on December 31, 1985, his final position being Chief of the Planning Staff at the Development Bank of the Philippines. His medical records indicated he suffered from bronchiectasis, emphysema, and hypertension as early as 1977. In June 1985, he was hospitalized for difficulty of breathing, fatigue, and cough, leading to his retirement at age 55. He filed a claim for compensation benefits with the GSIS.
The GSIS awarded him permanent partial disability benefits for eight months starting January 1986, solely on account of his essential hypertension. It ruled his bronchiectasis and emphysema were not work-connected but largely attributable to chronic cigarette-smoking. Naval sought reconsideration, insisting he was entitled to permanent total disability benefits, especially since the GSIS itself had evaluated him as permanently and totally disabled for retirement purposes. The GSIS denied his request, and the Employees’ Compensation Commission dismissed his appeal, prompting this petition.

ISSUE

Whether the respondent Commission erred in affirming the GSIS decision denying petitioner’s claim for permanent total disability benefits.

RULING

The Supreme Court affirmed the decision of the Employees’ Compensation Commission. The legal logic centers on the applicable provisions of the Labor Code (P.D. 442, as amended) and the petitioner’s burden of proof. Under Article 166, compensation is provided only for work-connected disability or death. The Court noted that the new Labor Code has abolished the presumption of compensability that existed under the old Workmen’s Compensation Act. Consequently, the claimant bears the burden of proving that the illness is work-related or that the risk of contracting it was increased by his working conditions.
The Court concurred with the findings of the GSIS and the Commission that petitioner’s bronchiectasis and emphysema were not work-connected but were caused by his chronic cigarette-smoking. While his essential hypertension was considered compensable, for which he duly received partial disability benefits, the Court found no evidence presented by petitioner to prove that this hypertension alone caused his permanent total disability. The medical evaluation indicated that all three ailments—bronchiectasis, emphysema, and hypertension—collectively contributed to his disabled condition. Furthermore, the nature of his “desk jobs” did not entail the stressful or strenuous activity that could be reasonably linked to causing or aggravating his hypertension. Since petitioner failed to discharge the burden of proving that his permanent total disability would exist even in the absence of the non-work-related lung ailments, the denial of permanent total disability benefits was proper.