GR L 45497; (October, 1979) (Digest)
G.R. No. L-45497 October 30, 1979
FEDERICO M. FAICOL, petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and the REPUBLIC OF THE PHILIPPINES (NATIONAL IRRIGATION ADMINISTRATION), respondents.
FACTS
Petitioner Federico M. Faicol was a government employee who served for 39 years, primarily with the National Irrigation Administration, retiring on January 12, 1974, at age 63, due to disability from hypertension with renal complication. His duties as an engineer involved extensive fieldwork, exposing him to environmental hazards. Medical records showed he had been suffering from hypertension since at least 1960, with the condition recurring and aggravating during his employment, culminating in chronic nephritis.
Subsequent to his retirement, Faicol filed a claim for disability benefits under the Workmen’s Compensation Act. His application was sent by registered mail on March 31, 1975. The Regional Office dismissed the claim, ruling it was filed after the reglementary period under the Labor Code. The Workmen’s Compensation Commission affirmed the dismissal, adding that Faicol, having optionally retired at 63, suffered no loss of earning power as he received full retirement benefits, and that hypertension was not an occupational disease.
ISSUE
The primary issues were: (1) whether the claim was filed within the reglementary period; (2) whether optional retirement precludes a claim for disability benefits under the Workmen’s Compensation Act; and (3) whether Faicol’s illness was compensable.
RULING
The Supreme Court reversed the Commission’s decision. On the first issue, the Court held the claim was timely filed. The Registry Receipt postmarked March 31, 1975, constituted conclusive proof of filing within the period prescribed by Article 292 of the Labor Code, as mailing is equivalent to filing.
On the second issue, the Court ruled that optional retirement does not bar a claim for disability compensation. Citing precedent, the Court explained that optional retirement under Commonwealth Act No. 660, as amended, is allowed only upon proof of physical incapacity to render efficient service. Therefore, the approval of Faicol’s optional retirement itself constituted an acknowledgment of his disability, negating the Commission’s finding of no loss of earning power. Entitlement to retirement benefits is separate from and not a bar to compensation benefits for work-connected disability.
On the third issue, the Court applied the rebuttable presumption of compensability under the Workmen’s Compensation Act. Faicol’s hypertension, which supervened and aggravated during his employment, is presumed to be work-related. The nature of his work, involving exposure to the elements, and the medical history of aggravation during employment, supported this presumption. The employer failed to present substantial evidence to rebut this presumption. Consequently, the illness was compensable. The Court ordered the National Irrigation Administration to pay Faicol compensation benefits, medical reimbursement, attorney’s fees, and administrative costs.