GR L 62284; (August, 1984) (Digest)
G.R. No. L-62284 August 31, 1984
DOLORES P. PORAL, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION, GOVERNMENT SERVICE INSURANCE SYSTEM (Ministry of Education and Culture), respondents.
FACTS
Petitioner Dolores P. Poral, a teacher, suffered from acute glaucoma starting in 1957, leading to an eye operation. She experienced recurring pain and blurring of vision, forcing frequent absences. In December 1972, severe pain necessitated another operation in Manila, which provided only temporary relief. Her vision never fully recovered, compelling her to apply for retirement in August 1977.
She filed a claim for disability benefits under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, contending that glaucoma is not an occupational disease but a common ailment of middle and advanced age. The Employees’ Compensation Commission (ECC) sustained the denial, prompting this petition.
ISSUE
Whether petitioner’s glaucoma is compensable under the governing law at the time her claim accrued.
RULING
The petition is granted. The Court ruled that the applicable law is the Workmen’s Compensation Act, not Presidential Decree No. 626, as the petitioner’s claim accrued prior to the effectivity of the new Labor Code. Under the old Act, a rebuttable presumption exists that an illness which supervened during employment arose out of or was aggravated by such employment. This presumption, rooted in social justice and protection to labor, places the burden on the employer to disprove compensability by substantial evidence.
Here, the respondents failed to present any evidence to rebut this legal presumption. Consequently, the presumption becomes conclusive. The cause of the ailment is immaterial; what is decisive is that it occurred or was aggravated in the course of employment. Following precedents like Sabino v. ECC, where a teacher’s glaucoma claim under the old law was granted, the Court held that petitioner had already acquired a vested right to compensation under the Workmen’s Compensation Act. The ECC decision was set aside. The Ministry of Education was ordered to pay petitioner Six Thousand Pesos (P6,000.00) as disability benefits and attorney’s fees.