GR L 51533; (November, 1983) (Digest)
G.R. No. L-51533 November 29, 1983
PAZ L. MAKABALI, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION, GOVERNMENT SERVICE INSURANCE SYSTEM (MINISTRY OF EDUCATION AND CULTURE), respondents.
FACTS
Petitioner Paz L. Makabali served as a classroom teacher from 1946 until her disability retirement in 1975. Her illness, glaucoma, manifested in 1971 with headaches and blurring vision. In August 1972, she collapsed while teaching, hitting the back of her head on the floor. She resumed work but suffered recurring headaches and eye pain, leading to ongoing treatment for glaucoma. She was forced to retire under the disability retirement plan before the compulsory retirement age. Subsequently, she filed a claim for disability benefits under P.D. No. 626, as amended.
The Government Service Insurance System (GSIS) denied her claim, asserting that glaucoma is not an occupational disease and is common in advanced age, with predisposing factors like arteriosclerosis and heredity. The Employees’ Compensation Commission (ECC) affirmed the denial, ruling that petitioner failed to present substantial evidence proving a causal link between her glaucoma and her teaching duties or that her working conditions increased the risk of contracting the ailment.
ISSUE
Whether petitioner’s glaucoma is compensable under the Employees’ Compensation Act despite not being listed as an occupational disease.
RULING
Yes. The Supreme Court reversed the ECC decision and granted the claim. The Court applied the principle of aggravation, holding that while glaucoma is not a listed occupational disease, the nature of a teacher’s work—involving constant use of the eyes for reading, checking papers, and other tasks—can reasonably aggravate an existing eye condition. The Court noted that her collapse at work and subsequent persistent symptoms indicated that her employment contributed to the progression of her disability.
Furthermore, the Court emphasized the constitutional precepts of social justice and protection to labor, adopting a liberal interpretation in favor of the employee. It ruled that her optional retirement under the disability plan itself constituted prima facie evidence of her work-related physical incapacity. The GSIS and ECC erred in imposing a stringent standard of proof for a non-listed disease; substantial evidence of work-connection or aggravation suffices. The Court ordered the payment of disability benefits, reimbursement for medical expenses, provision of rehabilitation services, attorney’s fees, and costs.