Facts:

The case involves Pablo A. Austria as the petitioner against the Court of Appeals and the Employees Compensation Commission (Social Security System) and Central Azucarera de Tarlac as respondents. Austria was employed as a bag piler at Central Azucarera de Tarlac from June 1, 1977, until July 20, 1997. His responsibilities included carrying and piling sacks of refined sugar, relocating stockpiles, assisting in production checks, cleaning the warehouse, and performing maintenance work. In 1994, he began experiencing severe back pain, leading to an MRI on November 18, 1994, which indicated a small disc protrusion at the L4 and L5 levels. Subsequently, he underwent a laminectomy on March 17, 1995. X-ray examinations conducted on May 23, 1997, September 3, 1998, and September 28, 1998, revealed osteoarthritis of the lumbar spine. Austria filed a claim for compensation benefits under Presidential Decree No. 626 (PD 626), which was granted, awarding him permanent partial disability...

Facts:

Employment Background

• Petitioner Pablo A. Austria was employed as a bag piler at Central Azucarera de Tarlac from June 1, 1977 to July 20, 1997.
• His assigned duties included:
• Carrying and piling sacks of refined sugar.
• Relocating and moving stock piles for shifting or returning to the refinery.
• Assisting the production checker in performing random weighing of production.
• Cleaning the warehouse, piling conveyor, and its surroundings.
• Assisting in repair and maintenance work during the off-season.
• Executing other related tasks as assigned by his superior.

Medical History and Initial Disability Benefits

• In 1994, petitioner began experiencing severe back pain.
• On November 18, 1994, an MRI revealed a small disc protrusion at the L4 and L5 levels.
• Petitioner underwent a laminectomy on March 17, 1995, at Ramos General Hospital in Tarlac.
• Subsequent x-ray photographs taken on May 23, 1997, September 3, 1998, and September 28, 1998, showed the presence of osteoarthritis of the lumbar spine.
• Based on the clinical and radiological findings, petitioner filed a claim with the SSS for compensation benefits under PD 626 as amended.
• The SSS granted his claim and awarded him permanent partial disability benefits in three installments:
• First release for eight (8) months starting September 1, 1995.
• Second release for seven (7) months starting May 10, 1996.
• Third release for fifteen (15) months starting April 1, 1997.

Request for Benefit Conversion

• After receiving permanent partial disability benefits, petitioner requested the conversion of his benefit to permanent total disability.
• The SSS denied this request, stating that:
• There was no progression of the illness beyond what had been assessed in the initial compensation.
• The findings on the lumbo-sacral x-ray were not sufficient basis for converting the benefit, as they indicated a different disease entity and had no direct relation.
• The Employees Compensation Commission (ECC) affirmed the SSS’s decision by holding that petitioner had already received the maximum benefits entitled to him on account of his osteoarthritis.

Procedural History

• Petitioner elevated his case to the Court of Appeals via a petition for certiorari, challenging the denial to convert his permanent partial disability benefit to permanent total disability benefit.
• The appellate court dismissed his petition, holding that the law does not allow the conversion of permanent partial disability benefits to permanent total disability benefits.
• Petitioner then filed a petition for review before the Supreme Court, raising the sole issue regarding the erroneous denial of benefits conversion.

Issue:

• Whether the Court of Appeals erred in denying petitioner’s claim for the conversion of his permanent partial disability benefit to a permanent total disability benefit.
• Whether the provisions under PD 626, as amended, and its supporting case law allow for the conversion of permanent partial disability benefits to permanent total disability benefits when the employee’s condition qualifies as such under the law.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)