G.R. No. L-44063 - Coras vs. Employees' Compensation Commission

Several petitioners—Corales, Villones, Caneja, and Barga—filed compensation claims concerning ailments and injuries which originated before the New Labor Code took effect.
The petitioners’ claims were initially processed under the provisions of the old Workmen’s Compensation Act (WCA), which is broader and more favorable than the new scheme under the New Labor Code.
The claims were filed with the Government Service Insurance System (GSIS) even though under the previous regime the respective government employers were originally liable for such claims.

In the Corales case, the petitioner started working in government service as early as 1932 and retired in 1975. His claim arose from contracting tuberculosis in 1965.
In Villones, the petitioner was a government teacher whose death in 1975 was linked to an ailment acquired in 1972, with his dependent filing a claim subsequently.
In the Caneja case, the petitioner, a government employee since 1950, filed his claim in 1976 for schizophrenia with multiple periods of confinement and treatment spanning from the early 1960s to mid-1970s.
In Barga, the petitioner, employed since 1959, experienced symptoms of duodenal ulcer in 1969 and underwent hospitalization and surgical procedures around early 1975.

The GSIS and the Employees’ Compensation Commission (ECC) had originally rejected the claims on the basis that the new Labor Code’s provisions were to be applied.
On appeal to the Supreme Court, the petitioners’ claims were favorably considered, as the Court applied the more compassionate provisions of the old WCA rather than the restrictive provisions of the new Labor Code.
Respondents filed several motions for clarification and reconsideration in connection with each case, raising points mostly on:

Determining the proper entity liable to pay the compensation benefits.
The legal implications of applying a ten-year prescriptive period (under the old law) versus the deadline stipulated by the New Labor Code.
The GSIS’s right to reimbursement from the respective government employers after payment of the awarded benefits.

The ECC questioned whether the GSIS should pay compensation benefits for claims based on causes of action accrued before January 1, 1975, contending that these benefits should be paid by the petitioners’ employers according to the old law.
The GSIS, while expressing willingness to pay, insisted on its right to reimbursement from the respective employers (for example, the Bureau of Lands, Commission on Audit, etc.), arguing that payment by GSIS would inadvertently reward employer negligence.
Additional issues included the interpretation of “sickness” under both the WCA and the Labor Code, and the impact of filing deadlines whose strict enforcement might violate vested rights grounded on social justice principles.

The decision consolidated the issues raised in Corales with similar issues in Villones, Caneja, and Barga, emphasizing that the determination of compensability should be based on the favorable provisions of the WCA.
Notable precedents and earlier resolutions (e.g., Ibanez vs. ECC, Pobre vs. WCC, and others) were relied upon as a basis for stressing the vested rights of claimants who suffered injuries or illnesses before the New Labor Code came into force.

Whether the Government Service Insurance System (GSIS) is liable to pay the compensation benefits or whether such payments should be made directly by the respective government employers (such as the Bureau of Lands or the Commission on Audit) as mandated under the old Workmen’s Compensation Act.
The implications of the filing of claims with a non-authorized office (GSIS instead of the appropriate regional office of the Department of Labor) and whether such act affects the legitimacy of the claim.

Determining the applicable law based on the time of accrual of the cause of action—specifically, whether the claim should be resolved under the old WCA, which offers broader compensability and a ten-year prescriptive period, or under the New Labor Code, which is more restrictive.
Clarification regarding the application of the prescriptive period and whether the deadline of March 31, 1975, should bar claims that accrued prior to the new regime but were filed later.

Whether the GSIS, upon paying the claims to the petitioners under the favorable provisions of the WCA, has a legal right to seek reimbursement from the negligent employers.
The proper procedure for the ECC to enforce such a right (including the need for a hearing to allow employers to present their defenses).