G.R. No. L-80382 November 29, 1988
DIONISIA ANTALLAN, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM and DEPARTMENT OF EDUCATION, CULTURE & SPORTS, respondents.

FACTS

Petitioner Dionisia Antallan commenced government service in 1949 as an elementary school teacher. In 1967, she began experiencing severe mental disturbances, including deep depression, auditory hallucinations, and insomnia, leading to a diagnosis of schizophrenia, residual type. Her condition progressively worsened, rendering her unable to perform her teaching duties, and she consequently retired on July 30, 1971, at age 47. Fourteen years after her retirement, in 1985, Antallan filed a claim for disability benefits with the Government Service Insurance System (GSIS) under the provisions of Presidential Decree No. 626, as amended (the Labor Code’s Employees’ Compensation Program).
The GSIS denied her claim, asserting it had jurisdiction only over claims of employees in service on or after January 1, 1975. The Employees’ Compensation Commission (ECC) affirmed the denial, ruling her case was beyond the coverage of P.D. 626 as her illness occurred in 1967 and she retired in 1971. The ECC further held that her claim, if cognizable under the old Workmen’s Compensation Act, was already barred by prescription.

ISSUE

The primary issue is whether Antallan’s claim for disability benefits is compensable under P.D. No. 626, as amended, or if it is barred by prescription under the applicable law.

RULING

The Supreme Court denied the petition and affirmed the ECC decision. The legal logic is anchored on the applicable law and the prescriptive period for filing claims. The Court first determined the governing law. Under Section 1(c), Rule III of the Amended Rules on Employees’ Compensation, only injury or sickness occurring on or after January 1, 1975, is compensable under P.D. 626. Since Antallan’s illness manifested in 1967 and she retired in 1971, her case is not covered by the present Labor Code provisions.
Consequently, the old Workmen’s Compensation Act (Act No. 3428) governs her claim. For claims accruing under this old law, the prescriptive period is ten years under Article 1144 of the Civil Code, counted from the time of disability. Antallan’s disability commenced upon her retirement in 1971, but she filed her claim only in 1985, or fourteen years later. Thus, her claim is indisputably barred by prescription.
The Court also rejected Antallan’s novel argument that her receipt of a monthly government pension maintained her status as a government employee for compensation coverage. A pension is a gratuity or act of liberality for past service, not equivalent to current wages or compensation for ongoing employment. Upon retirement in 1971, she ceased to be an employee rendering services; therefore, she was not an “employee” as defined under the compensation laws when P.D. 626 took effect. Her claim, having accrued under the old law and filed well beyond the ten-year prescriptive period, was correctly dismissed.