GR L 43276; (September, 1984) (Digest)
G.R. No. L-43276 September 28, 1984
Benedicta C. Daza, petitioner, vs. Republic of the Philippines (Bureau of Public Schools, now Ministry of Education, Culture & Sports) and Workmen’s Compensation Commission, respondents.
FACTS
Petitioner Benedicta C. Daza, a public school teacher from 1937 until her retirement on June 2, 1974, filed a claim for sickness compensation. She alleged she contracted various ailments in the course of her employment, which were aggravated by her work, forcing her to stop working. The Hearing Officer awarded her compensation benefits and medical reimbursement. The respondent Republic, through the Solicitor General, appealed.
The Workmen’s Compensation Commission (WCC) reversed the Hearing Officer’s decision and dismissed the claim. The Commission found that Daza’s service records indicated she opted for optional retirement at age 60, not disability retirement, and she had worked continuously without absences until her last day. Her physician’s report stated she was disabled for only two months, and the employer-employee relationship had ceased by the time of her claim.
ISSUE
Whether the Workmen’s Compensation Commission erred in dismissing Daza’s claim for compensation benefits.
RULING
The Supreme Court dismissed the petition, upholding the WCC’s decision. On procedural grounds, the Court found the Solicitor General’s petition for relief was filed within the reglementary period and substantially complied with the rules, considering the office’s tremendous workload.
Substantively, the Court affirmed the WCC’s factual findings, which are conclusive when supported by substantial evidence. The records showed Daza retired optionally at the statutory age, worked continuously without disability-related absences, and her physician certified only a two-month disability. Critically, the Court emphasized that to be compensable, an illness must affect earning capacity. Since Daza worked and received her pay until retirement, her ailments did not disable her from labor prior to the cessation of employment. Her claim thus lacked merit.
The Court also rejected the challenge to the WCC’s rules, ruling they were validly promulgated under the authority granted by the Workmen’s Compensation Act and have the force of law.