ARCADIA VISTAL, PETITIONER, VS. EMPLOYEES’ COMPENSATION COMMISSION, GOVERNMENT SERVICE INSURANCE SYSTEM (DEPARTMENT OF EDUCATION, CULTURE & SPORTS), RESPONDENTS.

Arcadia Vistal versus Employees' Compensation Commission

The Case

This is a petition for certiorari brought by Arcadia Vistal, a retired public school teacher, against the Employees' Compensation Commission and the Government Service Insurance System, impleading her former employer, the Department of Education, Culture and Sports. Vistal sought to reverse the Commission's dismissal of her claim for disability benefits for pulmonary tuberculosis, essential hypertension, and rheumatoid arthritis. The case matters because it fixes the dividing line between the old Workmen's Compensation Act and the new employees' compensation law, and because it shows how the Court resolves doubts in favor of the workingman.

Procedural History

Vistal filed her claim for disability benefits with the Government Service Insurance System, which denied it on the ground that she had retired from the service effective June 3, 1974, and that the System had jurisdiction only over claims of government employees still in the service on or after January 1, 1975. She appealed to the Employees' Compensation Commission. The Commission, in its decision dated January 7, 1987, dismissed the appeal for lack of jurisdiction, holding that the claim had been filed beyond the ten-year prescriptive period. Vistal then filed the present petition for certiorari before the Supreme Court, raising the grounds that her cause of action is governed by the Workmen's Compensation Act and that her ailments are compensable.

Facts

Arcadia Vistal was an elementary grades teacher in the Ministry of Education, Culture and Sports, Division of Bohol. She retired on June 3, 1974, at the age of 61. Sometime in 1973, while still employed, she contracted pulmonary tuberculosis, essential hypertension, and rheumatoid arthritis.

On September 9, 1983, she filed a claim for disability benefits under the present employees' compensation law. The Government Service Insurance System denied the claim, explaining that as administering agency of the Employees' Compensation Program, it had jurisdiction only over claims of government employees who were still in the service on or after January 1, 1975.

On appeal, the Employees' Compensation Commission held that because her ailments were contracted in early 1973, before the new decree took effect in 1975, her case was covered by the old Workmen's Compensation Act. Nevertheless, the Commission ruled that she could no longer pursue her case under the old law because her cause of action had already prescribed, her claim having been filed ten years after her cause of action accrued.

Issues

• Whether or not Vistal's claim is governed by the old Workmen's Compensation Act rather than the new employees' compensation law.
• Whether or not her claim had already prescribed when she filed it on September 9, 1983.
• Whether or not her ailments are compensable.
• Whether or not the Government Service Insurance System or her employer, the Department of Education, Culture and Sports, is legally bound to pay the claim.

Applicable Provisions

Article 208 of Presidential Decree 442, as amended by Presidential Decree 626, provides:

Article 208. Applicability. This Title shall apply only to injury, sickness, disability or death occurring on or after January 1, 1975.

This provision fixes the governing law by the date the ailment occurred, so that ailments contracted before January 1, 1975 fall under the old Workmen's Compensation Act.

Section 1(c) of Rule 111 of the Amended Rules on Employees Compensation provides:

Only injury or sickness that occurred on or after January, 1975 and the resulting disability or death shall be compensable under these Rules.

This rule confirms that the new compensation scheme reaches only injuries and sicknesses occurring on or after January 1, 1975.

Section 2 of Act Number 3428, as amended, provides:

Under the Workmen's Compensation Act, an employee is entitled to compensation benefits when he contracts an illness directly caused by such employment, or aggravated by or the result of the nature of such employment.

This is the standard of compensability applied to Vistal's ailments under the old law.

Section 44 of Act Number 3428, as amended, provides:

Moreover, the principle of presumption of compensability, although rebuttable by substantial evidence to the contrary, obtained under said law.

This presumption lightens the claimant's burden once the illness is shown to have arisen during employment.

Ruling

On the first issue, the Court held that the governing law is determined by the date on which the claimant contracted the illness. Where an ailment supervened before the new employees' compensation law took effect, the old Workmen's Compensation Act governs; where the ailment occurred after January 1, 1975, the new law applies. Since Vistal's ailments accrued in 1973, her claim falls under the old law. The Solicitor General, the Government Service Insurance System, and the Commission all agreed on this point.

On the second issue, the Court held that the claim had not prescribed. A claim under the Workmen's Compensation Act creates an obligation, and under Article 1144 of the Civil Code an action upon an obligation created by law must be brought within ten years from the time the right of action accrues. The records showed that the ailments accrued in 1973 without any specific date being stated. Applying the time-honored doctrine that any doubt must be resolved in favor of the worker, the Court construed the claim filed on September 9, 1983 as having been filed within the ten-year period. The Commission itself admitted that it erred in applying the prescriptive period.

On the third issue, the Court held that the ailments are compensable. There was no dispute that Vistal contracted the ailments during her employment, and the Court noted that tuberculosis may be considered an occupational disease or work-connected in occupations such as that of a teacher. It also relied on its earlier ruling that the optional retirement of a public school teacher on the ground of disability indicates physical incapacity to render efficient service. Vistal retired at the age of 61, and the Court concluded that her ailments are compensable.

On the fourth issue, the Court held that the employer, not the Government Service Insurance System, must pay. The System's jurisdiction covers only claims under the new law, which applies only to ailments occurring on or after January 1, 1975. Under the old law, employers are primarily and principally liable to pay the claims of their own employees. Following its earlier ruling, the Court held that where decisions decree awards under the Workmen's Compensation Act for ailments initially contracted before the effectivity of the new Labor Code, and the decisions have not yet become final, the awards shall be paid by the respective employers of the claimants.

Doctrine

The governing law in compensation cases is determined by the date the illness was contracted, not the date the claim was filed. Ailments contracted before January 1, 1975 are governed by the Workmen's Compensation Act; ailments occurring on or after that date fall under the new employees' compensation law, as Article 208 of Presidential Decree 442 and Section 1(c) of Rule 111 command.

A claim under the Workmen's Compensation Act creates an obligation, and the action to enforce it prescribes in ten years under Article 1144 of the Civil Code. Any doubt as to the date of accrual must be resolved in favor of the worker.

Under the old law, the employer is primarily and principally liable for the compensation award, while the Government Service Insurance System's jurisdiction is confined to claims under the new law.

Disposition

The petition was granted and the decision of the Employees' Compensation Commission was set aside; the Department of Education, Culture and Sports was ordered to pay Vistal 6,000 pesos as maximum compensation, 600 pesos as attorney's fees, and the administrative costs.

Remember This

Memorize the rule that the date of contraction of the illness, not the date of filing of the claim, determines whether the old Workmen's Compensation Act or the new employees' compensation law governs. Examiners use this case to test the ten-year prescriptive period under Article 1144 of the Civil Code and the rule that the employer, not the Government Service Insurance System, pays awards under the old law.