GR 97346; (March, 1992) (Digest)
G.R. No. 97346 . March 23, 1992.
Rodolfo Yosores, petitioner, vs. Employee’s Compensation Commission, respondent.
FACTS
Rodolfo Yosores was employed by the Government Service Insurance System (GSIS) for twenty-five years, from 1963 to 1988. He initially performed electrical work for a decade before being reassigned in 1973 as a Field Collection Officer, a role requiring him to travel throughout Metro Manila to collect payments from GSIS mortgagees. On July 31, 1988, Yosores retired due to total and permanent disability diagnosed as Parkinson’s Disease, as certified by GSIS senior officials including its Medical Director. He filed a claim for compensation benefits, but the GSIS granted only a limited award for a different ailment (pulmonary tuberculosis) and later denied his claim for Parkinson’s, asserting it was not work-connected. The Employee’s Compensation Commission (ECC) affirmed the denial, ruling the disease had no causal relation to his work as a field officer.
ISSUE
Whether Parkinson’s Disease suffered by Yosores is compensable under Presidential Decree No. 626, as amended.
RULING
Yes. The Supreme Court reversed the ECC decision and declared the ailment compensable. The Court rejected the ECC’s sweeping conclusion that Parkinson’s Disease had no causal relation to Yosores’ employment. Medical authorities cited in the decision indicate that factors such as emotional excitement, trauma, and overwork can be predisposing or exciting factors for the disease. As a Field Collection Officer for fifteen years, Yosores’ job involved constant commuting, exposure to the elements, and inherent stresses, which could constitute such aggravating factors. Furthermore, the Court noted he had developed hypertension with tremors and anxiety neurosis in 1967, during his employment. This paralleled the ECC’s own prior rulings in similar cases (e.g., Chungalao), where hypertensive cardiovascular disease was found to have triggered Parkinson’s and was deemed causally connected to employment conditions. The Court found no substantial distinction between those precedents and Yosores’ case. Therefore, his total and permanent disability resulting from Parkinson’s Disease is compensable under the law.