GR L 44063; (February, 1979) (Digest)
G.R. No. L-44063 February 27, 1979
VICTORIANO F. CORALES, petitioner, vs. EMPLOYEES COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.
FACTS
Petitioner Victoriano F. Corales, a land investigator, contracted tuberculosis (PTB) in September 1965. Despite his illness, he continued working without significant absence until his compulsory retirement at age 65 on March 27, 1975. A medical certificate confirmed he was still suffering from moderately advanced PTB at retirement. He filed a claim for disability compensation and reimbursement of medical expenses under the workmen’s compensation laws.
The Employees’ Compensation Commission and the Government Service Insurance System (GSIS) denied his claim. They argued his ailment was not occupational, he failed to prove increased risk from his work conditions, and the presumptions of compensability under the old Workmen’s Compensation Act no longer applied under the new Labor Code. The Supreme Court initially rendered a decision on August 25, 1978, granting medical reimbursement and services but denying disability compensation because he suffered no wage-loss, having worked until retirement.
ISSUE
The core issue in the motions for reconsideration is whether the petitioner’s claim for compensation, stemming from an illness contracted in 1965, is governed by the old Workmen’s Compensation Act or the new Labor Code, and consequently, whether he is entitled to the awarded benefits.
RULING
The Court denied the motions for reconsideration, upholding its original decision. The legal logic is anchored on the applicable law. The Court clarified that the petitioner’s cause of action accrued in September 1965 when he contracted PTB, which was well before the effectivity of the New Labor Code on January 1, 1975. Article 294 of the New Labor Code’s transitory provisions mandates that claims accruing prior to its effectivity shall be determined under the laws in force at the time of accrual. Therefore, the Workmen’s Compensation Act, as amended, governs this claim.
Under the old Act, the Court found clear and convincing evidence that the risk of contracting tuberculosis was increased by the conditions of his work as a land investigator. This established compensability. The award for reimbursement of medical expenses and provision of medical services is justified independently of any wage-loss, as workmen’s compensation benefits include payment for hospital and medical expenses occasioned by a work-connected injury or illness. The denial of disability compensation was maintained because such compensation is intended to replace lost earning capacity. Since the petitioner worked continuously until retirement without wage-loss, no disability compensation was due. The Court affirmed that sympathy cannot amend the law’s clear provisions.