GR 93561; (May, 1991) (Digest)
G.R. No. 93561 ; May 6, 1991
CANDIDO A. DALUPE, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.
FACTS
Petitioner Candido A. Dalupe served as a patrolman from 1948 until his compulsory retirement in 1980. During his service, he contracted malignant hypertension, hypertensive cardiovascular disease, and cystitis. In 1985, he filed a claim for compensation benefits with the GSIS, which was approved. He was awarded benefits for Permanent Partial Disability for a period of eight months.
Subsequently, Dalupe requested the conversion of his disability classification to Permanent Total Disability. The GSIS denied this request, stating he had already received the maximum benefits corresponding to his disability’s degree. This denial was affirmed by the Employees’ Compensation Commission (ECC), prompting Dalupe to elevate the case to the Supreme Court via a petition for review on certiorari.
ISSUE
The sole issue is whether the disability resulting from the petitioner’s ailments should be classified as permanent and total, thereby warranting the conversion of his benefits.
RULING
The Supreme Court denied the petition, upholding the classification of Permanent Partial Disability. The Court emphasized that the GSIS Medical Director is the official authorized by law to determine the nature and degree of a claimant’s disability, subject to ECC approval. The petitioner relied primarily on the opinion of his attending physician, Major Felix M. Reyes, Jr., but failed to submit corroborating certifications from other physicians who had attended to him during his hospitalizations.
The Court found that the GSIS and ECC correctly applied the specific criteria and ratings outlined in Appendix “E” of the ECC Schedule of Compensation for Hypertensive Cardiovascular Disease. This schedule provides that for a rating of Permanent Total Disability, the patient must have continued hypertension that no longer falls to normal even at rest, with demonstrable evidence of cardiovascular disease and greatly limited physical activity. The award for Permanent Partial Disability was based on an assessment of Dalupe’s condition at the time of his retirement, which did not meet the stricter criteria for total disability as defined by the schedule.
While the Constitution mandates a compassionate policy towards labor, the Court ruled that such policy cannot override the specific provisions of the applicable law and the evidence on record. Since the petitioner did not substantiate his claim for total disability according to the established legal criteria, and no abuse of discretion was found in the respondents’ actions, the petition was denied.