Case Digest (G.R. No. 148323)
Facts:
Bernandino S. Manioso was employed in government service from July 13, 1959 until compulsory retirement on May 15, 1995, having served almost thirty six (36) years. He was diagnosed with Hypertensive Vascular Disease (HVD) in 1978 and with Coronary Artery Disease (CAD) in 1983, and later found to have Nephrolithiasis and other renal and related conditions.
In 1995, petitioner was hospitalized in Batangas City from January 11, 1995 up to January 20, 1995 after chest heaviness, shortness of breath, and diaphoresis, with findings of Acute Myocardial Infarction and HVD. He was on sick leave until his retirement, and the GSIS initially granted Temporary Total Disability (TTD) benefits for two months (January 11 to March 11, 1995) and Permanent Partial Disability (PPD) benefits for eight months (May 15, 1995 to January 14, 1996). When petitioner sought additional disability benefits after further hospitalizations in 1997, the GSIS denied the claim, and the Court of Appeals affirmed, holding that petitioner’s condition at retirement did not meet Permanent Total Disability (PTD) criteria and that his later ailments could no longer be attributed to his occupation.
Issues:
- Whether petitioner’s ailments, including Acute Myocardial Infarction and Hypertensive Vascular Disease and other later-developing conditions, fall under Permanent Total Disability (PTD).
- Whether petitioner’s retirement from service prevents him from entitlement to PTD benefits.
Ruling:
The Court reversed and set aside the assailed decisions and declared petitioner’s disability permanent and total, ordering the GSIS to pay his benefits arising therefrom.
The Court held that petitioner met the conditions for PTD because his work-related disability lasted for more than 120 days, and it rejected the notion that retirement barred the benefits. It further held that the 1997 ailments were complications arising from his work-related conditions, so compensation coverage extended to the disease supervening thereafter.
Ratio:
On the first issue, the Court applied Article 192(c) of PD No. 442, as amended (Labor Code) and the criterion under Section 2(b), Rule VII of the Amended Rules on Employees Compensation, requiring an inability to perform any gainful occupation for a continuous period exceeding 120 days. Since petitioner was on sick leave from January 11, 1995 to his retirement on May 15, 1995, or for more than 120 days, the Court concluded that he was entitled to PTD benefits, notwithstanding the GSIS’s classification of his disability as PPD.
On the second issue, the Court ruled that entitlement to benefits for work-related sickness continues until the employee becomes gainfully employed, recovers, or dies, none of which was shown in petitioner’s case. It added that denying benefits to a government employee who had served for thirty six (36) years would be an affront to justice, given the work-related nature of his condition and its proximately related complications.
Doctrine:
- Under Article 192(c) of the Labor Code and Section 2(b), Rule VII of the Amended Rules on Employees Compensation, disability is total and permanent when, as a result of sickness, the employee is unable to perform any gainful occupation for a continuous period exceeding 120 days.
- The PTD right covers not only the initial compensable condition but also disability due to disease that supervenes and proximately and naturally results from the compensable injury or sickness.
- Retirement from government service does not bar PTD benefits for work-related sickness where the conditions for continued compensation under the law have not ceased by gainful employment, recovery, or death.