Facts:

The case involves Bonifacia M. Calvero as the petitioner against the Employees' Compensation Commission (ECC) and the Government Service Insurance System (GSIS) as respondents. The events leading to this case began when Calvero, who had a long-standing career in the government service starting as a temporary classroom teacher on July 28, 1941, was eventually promoted to the position of District Supervisor in Dagupan. Her medical issues began to surface on June 12, 1971, when she experienced symptoms of multiple sclerosis after participating in an Independence Day Parade. Over the years, her condition worsened, leading to significant mobility issues, and she was forced to retire on November 1, 1977, at the age of 55.

Following her retirement, Calvero filed a claim for disability benefits under Presidential Decree No. 626 in January 1978, which was denied by the GSIS on March 28, 1978, on the grounds that multiple sclerosis was not classified as an occupational disease. ...

Facts:

1. Employment Background:

   • Bonifacia M. Calvero began her government service on July 28, 1941, as a temporary teacher in Dagupan. She was later given a permanent appointment on July 1, 1947, and was promoted to various positions, including elementary school principal and eventually district supervisor. Her duties were primarily administrative and supervisory.

2. Medical History:

   • On June 12, 1971, Calvero first experienced symptoms of her ailment, described as "hotness and heaviness in the sole of her feet," after participating in the Independence Day Parade. These symptoms persisted intermittently until March 14, 1974, when she reported difficulty in locomotion, stiffness, numbness, tingling, and continuous hot sensations from her soles to her waist. She was treated by multiple physicians, and her condition was eventually diagnosed as multiple sclerosis by a neurologist, Dr. Luz Pulmano Mabanag.

3. Retirement and Claim:

   • Due to her deteriorating health, Calvero retired on November 1, 1977, at the age of 55. She filed a claim for disability benefits under Presidential Decree No. 626, as amended, with the Government Service Insurance System (GSIS) in January 1978. The GSIS denied her claim, stating that multiple sclerosis is not an occupational disease and that there was no evidence linking her condition to her employment.

4. Appeal to ECC:

   • Calvero appealed to the Employees' Compensation Commission (ECC), which affirmed the GSIS decision. The ECC ruled that her ailment was not listed as an occupational disease and that there was no substantial evidence showing that her employment increased the risk of contracting multiple sclerosis.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Presumption of Compensability:

   • Under the Workmen's Compensation Act, if an ailment supervenes during employment, it is presumed to be compensable unless the employer provides substantial evidence to the contrary. In this case, no such evidence was presented, making the presumption conclusive.

2. Nature of Employment and Risk Factors:

   • The Court recognized that Calvero's work as a teacher and district supervisor exposed her to physical and environmental stressors that could have contributed to the development or aggravation of her ailment. Even if the exact cause of multiple sclerosis is unknown, the employment conditions increased the risk of contracting or worsening the disease.

3. Applicability of the Workmen's Compensation Act:

   • Since the cause of action accrued before the New Labor Code took effect, the more favorable provisions of the Workmen's Compensation Act apply. The ten-year prescriptive period under the Act was also upheld.

4. Social Justice and Labor Protection:

   • The Court emphasized the importance of social justice in labor cases, ruling that doubts in the interpretation of labor laws should be resolved in favor of the worker. The decision reflects the Court's commitment to protecting employees' rights, especially in cases involving occupational diseases and disabilities.

Conclusion:

The Supreme Court set aside the decision of the Employees' Compensation Commission and ordered the GSIS to pay Calvero disability compensation benefits, reimburse her medical expenses, and provide rehabilitation services. The GSIS was also granted the right to seek reimbursement from the employer after due process. The ruling reaffirmed the presumption of compensability under the Workmen's Compensation Act and highlighted the Court's commitment to social justice in labor disputes.