Title
Raro vs. Employees' Compensation Commission
Case
G.R. No. 58445
Decision Date
Apr 27, 1989
Zaida Raro, a government clerk, claimed disability benefits for a brain tumor contracted during employment. The Supreme Court denied her claim, ruling that brain tumor is not a listed occupational disease and she failed to prove her work increased the risk, affirming the burden of proof under current compensation laws.
A

Case Digest (G.R. No. 58445)

Facts:

Zaida G. Raro v. Employees' Compensation Commission and Government Service Insurance System (Bureau of Mines and Geo-Sciences), G.R. No. 58445, April 27, 1989, Supreme Court En Banc, Gutierrez, Jr., J., writing for the Court.

The petitioner, Zaida G. Raro, was employed by the Bureau of Mines and Geo-Sciences at its Daet, Camarines Norte regional office, hired on March 17, 1975, and later served as a Mining Recorder II. About four years into her employment she developed severe and recurrent headaches with blurring of vision; subsequent medical evaluation at Makati Medical Center diagnosed her condition as a brain tumor that impaired memory, vision and reasoning. Her husband filed a claim for disability benefits with the Government Service Insurance System (GSIS) on January 7, 1980 (as summarized in the dissent), which the GSIS denied on November 24, 1980; the GSIS also denied a motion for reconsideration.

Petitioner appealed to the Employees' Compensation Commission (ECC). The ECC affirmed the GSIS denial in ECC Case No. 1692 (decision dated August 27, 1981), concluding that brain tumor was not a compensable occupational disease under the applicable law and rules. Petitioner sought review by the Supreme Court by petition for review on certiorari. The Supreme Court, sitting En Banc, resolved the petition; the majority opinion was authored by Justice Gutierrez, Jr. The Court considered statutory provisions (notably the Labor Code definition of "sickness" in Presidential Decree No. 422, Art. 167, and the Amended Rules on Employees' Compensation, Rule III, Sec. 1(b)), prior decisions...(Subscriber-Only)

Issues:

  • Whether a brain tumor of unknown causes contracted during employment is compensable under the present employees' compensation law.
  • Whether the presumption of compensability (and related doctrines under the old Workmen’s Compensation Act) remains applicable when a disease is not listed as an occupational diseas...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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