G.R. No. 89097 August 24, 1990
ANGELO L. LOYOLA, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM AND EMPLOYEES’ COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Angelo L. Loyola, a District Supervisor for the Department of Education, Culture and Sports, entered government service in 1962. In 1987, he contracted an eye ailment characterized by progressive blurring of vision, which was diagnosed as cataract with glaucoma in his left eye. He underwent cataract extraction surgery and subsequently filed a claim for compensation benefits with the GSIS under Presidential Decree No. 626, as amended.
The GSIS disapproved his claim, ruling that his ailment was a non-work-connected degenerative condition. His motion for reconsideration was denied. On appeal, the Employees’ Compensation Commission affirmed the GSIS decision, holding that senile cataract and glaucoma are associated with the aging process and that there was no proof of a causal relationship between his ailments and his occupation as a teacher and supervisor.

ISSUE

Whether petitioner’s illness, cataract with glaucoma, is compensable under the Employees’ Compensation Act.

RULING

Yes, the illness is compensable. The Court reversed the ECC decision. Under P.D. No. 626, for a non-listed illness like cataract with glaucoma to be compensable, the claimant must prove, by substantial evidence, that the risk of contracting the disease was increased by his working conditions. The Court abandoned the doctrine of presumptive compensability; the claimant bears the burden of proof.
The ECC correctly noted that senile cataract is commonly associated with aging. However, the Court found that petitioner successfully discharged his burden of proof. He submitted his attending physician’s certificate and official statements from his superintendent detailing his duties. These documents established that as District Supervisor and Athletic Manager, his work required extreme and frequent exposure to environmental conditions like the direct heat of the sun, dust, rain, and strong winds while officiating and supervising athletic events.
The Court applied the principle from Cerezo vs. ECC and Jarillo vs. ECC, which holds that even if advancing age contributed to the development of the ailment, compensability is established if the employment contributed to or aggravated the condition. Here, the nature of petitioner’s duties, involving prolonged outdoor exposure, contributed to or aggravated his eye ailment. Therefore, he is entitled to compensation benefits and attorney’s fees.