GR L 45456; (March, 1985) (Digest)
G.R. No. L-45456 March 18, 1985
Regina A. Afable, petitioner, vs. Workmen’s Compensation Commission and The Department of Education and Culture, respondents.
FACTS
Petitioner Regina A. Afable, a public school teacher for 33 years, stopped working on July 16, 1974, at age 62 due to multiple ailments including diabetes mellitus, cardiomegaly with hypertension, and pulmonary tuberculosis. She applied for retirement with the GSIS, describing her physical disabilities, and was granted disability retirement pay. Subsequently, she filed a claim for disability benefits under the Workmen’s Compensation Act.
The Regional Office dismissed her claim, reasoning that her application for optional retirement precluded an allegation that she stopped work due to illness. The Workmen’s Compensation Commission affirmed this dismissal. The core dispute centered on whether she could claim statutory disability benefits in addition to her GSIS retirement compensation and whether her illnesses were work-connected.
ISSUE
The primary issue is whether a public school teacher who received GSIS disability retirement pay is still entitled to disability benefits under the Workmen’s Compensation Act for service-connected ailments.
RULING
The Supreme Court reversed the Commission’s decision and granted the claim. On the first issue, the Court held that entitlement to GSIS benefits does not bar a claim under the Workmen’s Compensation Act. Section 3 of the Act explicitly provides that government employees insured with the GSIS are entitled to the benefits of both systems. The records confirmed she retired due to disability, not merely under the optional plan.
On the second issue, the Court ruled her disabilities were compensable as work-connected. Her physician’s report attributed her illnesses to strenuous mental and physical activities over her 33-year teaching career. The ailments supervened during employment, giving rise to the rebuttable presumption under Section 44(1) of the Act that they arose out of or were aggravated by her work. The employer failed to rebut this presumption. Specifically, pulmonary tuberculosis is compensable under the Act, hypertension has been held compensable for teachers due to occupational strains, and her diabetes mellitus was linked to her other compensable conditions. Therefore, her disability was service-connected. Respondent was ordered to pay petitioner P6,000.00 in disability benefits.