G.R. No. L-65856 January 17, 1986
ROQUE V. ZOZOBRADO, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (Ministry of Public Works), respondents.

FACTS

Roque Zozobrado served as a civil engineer in the government from 1958 until his retirement in 1979 at age 63. His career culminated in the position of District Engineer. He retired due to glaucoma and cataract, having undergone operations for glaucoma in 1967 and 1970, and for a mature cataract in his left eye in 1978. Upon retirement, he received a retirement gratuity but subsequently filed a claim for total and permanent disability benefits with the GSIS.
The GSIS denied his claim, ruling that glaucoma and cataract are not occupational diseases under Presidential Decree No. 626, as amended. Zozobrado moved for reconsideration, arguing his work—reviewing plans, specifications, and cost estimates, resolving field disputes, and performing supervisory duties—required constant visual strain which caused or aggravated his condition. The GSIS and, on appeal, the Employees’ Compensation Commission (ECC), affirmed the denial. The ECC held that his senile cataract resulted from degenerative changes due to aging, not his employment, and that his duties did not increase the risk of contracting the disease.

ISSUE

Whether petitioner’s senile cataract is compensable under the Employees’ Compensation Act (PD 626, as amended).

RULING

No. The Supreme Court affirmed the ECC’s decision denying the claim. The applicable law is PD 626, which abandoned the old Workmen’s Compensation doctrine of presumptive compensability. For a sickness to be compensable, it must either be a listed occupational disease with the attendant conditions satisfied, or the claimant must prove by substantial evidence that the risk of contracting the disease was increased by the working conditions.
Senile cataract is not a listed occupational disease under the law. Medical authorities define it as an opacity of the lens occurring after age fifty due to degenerative changes associated with the aging process. It is a physiological hazard to which all persons are exposed, regardless of occupation. The Court found that Zozobrado failed to establish a causal link between his duties as a District Engineer and the development of his cataract. His claim that constant visual strain from his work caused the ailment was insufficient to meet the required standard of proof. The nature of his employment did not subject him to conditions, such as exposure to intense glare from molten materials, that would increase the risk of developing a compensable cataract. Therefore, his ailment was not work-related and was correctly deemed non-compensable.