G.R. No. 62406 - Medina vs. Employees' Compensation Commission

Petitioner Gregorio Medina was a long-time government employee who began his service in 1947.
At the time of his retirement on December 1, 1980, he held the position of senior trade promotion and regulation officer at the Bureau of Domestic Trade in Batangas City.

On July 18, 1980, after attending a conference in Quezon City, Medina was involved in an accident on his way home at 5:30 P.M. at Barrio Payapa, Lemery, Batangas.
As a result of the accident, he sustained severe head injuries medically identified as a subdural hematoma (fronto parietal, right side).
He underwent craniotomy at the Makati Medical Center and was hospitalized from August 29 until September 11, 1980.

Owing to the gravity of his injuries, Medina was forced to retire early at the age of 55.
He received retirement benefits amounting to P45,516.53.

Medina filed a claim for disability compensation under P.D. 626, as amended, with the Government Service Insurance System (GSIS).
GSIS initially granted him income benefits of P1,500.00 corresponding to a temporary total disability.
Upon petitioning further, GSIS reclassified his condition as permanent partial disability (PPD) and awarded additional income benefits amounting to P14,634.60 for a period of 15 months, from July 1980 to September 1981.
Consequently, the total award reached P16,134.60, and, following further motions, GSIS reimbursed his hospital expenses in the amount of P5,708.22.

After the third and final motion for reconsideration was denied by GSIS, Medina elevated his appeal to the ECC.
The ECC, while affirming the GSIS findings, maintained that Medina’s disability was classified as a 25% non-scheduled, permanent partial disability.
The ECC noted that although the period for benefits should be increased pursuant to Sec. 7 of PD 1368, the available award reflected only permanent partial disability benefits.

Medina argued that the certification of his attending physician, Dr. Romeo Gustilo—a well-known neurologist and chairman of the Department of Neurological Sciences at Makati Medical Center—substantiated that his disability was, in fact, permanent total disability.
The physician’s report described Medina’s condition as “total disability,” noting that due to an extensive hemorrhagic pathology, he might develop future mental and neurological deficits.
Medina contended that he suffered mental lapses that rendered him incapable of performing any gainful work, necessitating his early retirement.
Relying on Article 192 of the New Labor Code and precedents such as Galang vs. WCC, he argued that an employee forced to retire due to disability is entitled to benefits for permanent total disability, which should cover the remaining days until the normal retirement age.

Whether the petitioner’s disability should be classified and compensated as permanent total disability under Article 192 of the New Labor Code or as permanent partial disability as indicated by GSIS and affirmed by the ECC.

The weight and credibility of the attending physician’s (Dr. Romeo Gustilo’s) certification in establishing total disability.
Whether Medina’s condition, which includes functional loss due to hemiparesis, meets the criteria for permanent total disability despite the absence of complete paralysis.
The appropriateness of relying on administrative and non-expert medical evaluations (from GSIS and ECC) versus expert clinical opinion in determining the nature and extent of the disability.