MALLI A. HATTA HATAIE (DECEASED), SUBSTITUTED BY EDWIN O. HATTA, PETITIONER, VS. EMPLOYEES’ COMPENSATION COMMISSION, GOVERNMENT SERVICE INSURANCE SYSTEM, RESPONDENTS.

Hatta versus Employees' Compensation Commission

The Case

This is a petition by Malli A. Hattaie, later substituted by Edwin O. Hatta as executor of his estate, against the Employees' Compensation Commission and the Government Service Insurance System. The petitioner sought disability benefits for an eye ailment called neovascular glaucoma, which both the System and the Commission refused to recognize as compensable. The case matters because it draws a sharp line between the old Workmen's Compensation Act and the present Employees' Compensation Law, and because it teaches how a claimant must prove compensability when the illness is not on the list of occupational diseases.

Procedural History

The petitioner filed his disability benefit claim with the Government Service Insurance System under Presidential Decree Number 626. The System denied the claim. The Employees' Compensation Commission affirmed the denial. From that adverse ruling, the petitioner came to the Supreme Court by petition for review on certiorari under Rule 45 and Article 181 of the Labor Code. The Court gave the petition due course. While the case was pending, the original petitioner died, and the Court allowed the executor of his estate to be substituted in his stead.

Facts

The petitioner entered government service as a legal aide in September 1958. He later became an administrative assistant of an office abolished by executive order in August 1964, and then transferred to the Bureau of Customs as Senior Executive Assistant. He rose through various positions until he became a Collector of Customs on the first of January 1987, and he held that position until his retirement on the first of June 1988.

Sometime in 1985, before his retirement, he experienced blurring of vision accompanied by eye pain and photophobia. The condition was diagnosed as neovascular glaucoma. Because his vision kept deteriorating, he underwent four eye operations, all without success.

He then filed a disability benefit claim with the Government Service Insurance System. The System denied the claim, and the Employees' Compensation Commission affirmed, finding that glaucoma is chiefly due to the structure of the eye itself, that its underlying cause is not work-related, and that there was neither proof of compensability in relation to his occupation nor an increased risk in his working conditions. Before the Supreme Court, the petitioner argued that his work as head of the Legal and Investigation Staff of the Bureau of Customs entailed reading voluminous documents, often under strong light or with a magnifying glass, producing severe eye strain that developed into neovascular glaucoma.

Issues

• Whether or not neovascular glaucoma is compensable as an occupational disease under the Employees' Compensation Law.
• Whether or not the petitioner proved that the risk of contracting neovascular glaucoma was increased by his working conditions.
• Whether or not the earlier cases allowing compensation for glaucoma apply to his claim.

Applicable Provisions

Article 167 of the Labor Code, as amended by Presidential Decree Number 626 and further by Presidential Decree Number 1368, defines the grounds for disability benefits:

To be entitled to disability benefits under the Employees' Compensation Law (Book Four, Title II, Labor Code, as amended by PD. No. 626), there must be "loss or impairment of a physical or mental function" which has resulted from an injury "arising out of or in the course of employment," or from "any illness definitely accepted as an occupational disease listed by the Commission, or any illness caused by employment subject to proof that the risk of contracting the same is increased by working conditions" (Art. 167 [n], [k] and [l], as amended further by PD No. 1368).

This provision fixes the petitioner's burden, because neovascular glaucoma is not in the Table of Occupational Diseases, so he must prove that his working conditions increased the risk of contracting it.

Ruling

On the first issue, the Court held that neovascular glaucoma is not compensable in this case. It is classified as secondary glaucoma, caused by another eye disease or injury, and the petitioner never showed that his ailment was caused or even preceded by another eye disease or injury. Severe eye strain from reading, the Court said, is neither a disease such as an infection nor an injury such as trauma.

On the second issue, the Court held that the petitioner failed to establish that his eye strain increased the risk of contracting the ailment, or that it caused, contributed to, or increased the risk of any other eye disease or injury that might have developed into neovascular glaucoma. There was no relation between his work as Collector of Customs and the illness.

On the third issue, the Court held that the cases he invoked did not apply. The earlier decisions allowing compensation to teachers afflicted with glaucoma rested on a presumption under the old Workmen's Compensation Act, which was repealed on the first of January 1975 by Presidential Decree Number 626, and those cases spoke of primary glaucoma, not secondary. In the Commission case he cited, the claimant's eye had been struck by the corner of a car door, an evident trauma that caused the glaucoma. In the other case, the illness actually held compensable was cataract, not glaucoma.

Doctrine

Under the Employees' Compensation Law, a claimant must show loss or impairment of a physical or mental function resulting from an injury arising out of or in the course of employment, or from an illness listed as an occupational disease, or from any illness caused by employment where the risk of contracting it is increased by working conditions. When the illness is not in the Table of Occupational Diseases, the claimant bears the burden of proving that positive proposition, that the risk of contracting the disease is increased by the working conditions. Ordinary eye strain from reading is neither a disease nor an injury and cannot supply that proof. Finally, the presumption of compensability under the repealed Workmen's Compensation Act no longer applies.

Disposition

The petition was denied and the decision of the Employees' Compensation Commission was affirmed, so the respondents prevailed and no benefits were awarded.

Remember This

Memorize this line: an illness not listed as an occupational disease is compensable only upon proof that the risk of contracting it is increased by the working conditions. Examiners use this case to test the shift from the old presumption of compensability to the strict proof required under the Employees' Compensation Law, and to test whether a claimant can distinguish primary from secondary glaucoma.