Title
Tria vs. Employees' Compensation Commission
Case
G.R. No. 96787
Decision Date
May 8, 1992
A retired postmaster sought to convert his partial disability benefits to total disability due to ischemic heart disease, but the Supreme Court denied his claim, citing inconsistent evidence and lack of work-connected recurrence.

Case Digest (G.R. No. 112796)

Facts:

  • Employment and Service Record
    • Petitioner entered the Bureau of Posts as a letter carrier in August 1964.
    • He was promoted to the rank of Postmaster I in November 1987.
    • He served in the government service for almost twenty (20) years until his retirement on October 1, 1984.
  • Onset of Medical Condition and Initial Claim
    • Several months before his retirement, petitioner began experiencing recurring attacks of fainting, headache, occasional loss of consciousness, and amnesia.
    • Upon consulting a private medical practitioner, his condition was diagnosed as Ischemic Heart Disease.
    • An electrocardiogram (ECG) taken at the GSIS medical clinic showed non-specific ST-R changes.
    • On April 26, 1985, petitioner filed a claim under P.D. No. 626, as amended, and was then awarded permanent partial disability (PPD) benefits for eight (8) months (from October 1984 to May 1985).
  • Subsequent Dissatisfaction and Requests
    • Not satisfied with the benefit award, petitioner sent a series of letters to the GSIS claiming additional benefits.
    • These requests were denied by the GSIS, with the explanation that the awarded benefit was commensurate to his condition at the time of separation.
  • Request for Reemployment
    • On April 10, 1987, petitioner sought reemployment by writing to the Regional Director, Postal Region IV, stating that he had “fully recovered” from his ailment as of 1985 and had been engaged in farming and poultry-raising.
    • The reemployment request was denied due to the absence of a job vacancy.
  • Petition for Conversion of Disability Benefits
    • On February 25, 1988, petitioner wrote another letter to GSIS requesting the conversion of his PPD benefits to permanent total disability (PTD) benefits, claiming a recurrence of his ailment.
    • He supported his claim with two medical certificates (dated February 15, 1988, and January 23, 1991) issued by the Municipal Health Officer of Roxas, Oriental Mindoro.
    • GSIS denied the conversion request, stating that his case did not meet the criteria for PTD, since the disability was assessed based on the physical condition at the time of separation from service and not from subsequent changes.
  • Elevation and Review of the Case
    • Upon petitioner’s request, the case was elevated for review to the Employees’ Compensation Commission (ECC).
    • The ECC affirmed the decision of GSIS, leading petitioner to file a petition for certiorari with the Court.

Issues:

  • Conversion of Disability Benefits
    • Whether petitioner’s disability benefits may be converted from permanent partial disability (PPD) to permanent total disability (PTD) in light of the alleged recurrence of his illness.
  • Interpretation of the Workmen's Compensation Law
    • Whether the Workmen’s Compensation Law should be liberally construed in petitioner’s favor, considering the conflict between his claim of recurrence and his earlier statements of recovery and reemployment.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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