JOSE DE GUIA, PETITIONER, VS. EMPLOYEES’ COMPENSATION COMMISSION AND GOVERNMENT SERVICE INSURANCE SYSTEM, RESPONDENTS.

De Guia versus Employees' Compensation Commission

The Case

This is a petition for review on certiorari filed by Jose de Guia, a retired Supervising Revenue Enforcement Officer of the Bureau of Internal Revenue, against the Employees' Compensation Commission and the Government Service Insurance System. He asks the Supreme Court to reverse the denial of his claim for compensation benefits for his eye ailment, proliferative diabetic retinopathy with vitreous hemorrhage, under the employees' compensation law. The case matters because it fixes the burden of proof for ailments that are not listed occupational diseases, and it draws the line between a work-related illness and a mere complication of a personal, pre-existing disease.

Procedural History

De Guia filed his claim for compensation benefits with the Government Service Insurance System, which denied it on the ground that his underlying ailment, diabetes mellitus, is not an occupational disease and that no causal link to his working conditions was shown. He appealed to the Employees' Compensation Commission, which affirmed the denial. He then came to the Supreme Court by petition for review on certiorari under Rule 45 of the Rules of Court and Article 181 of the Labor Code, filed on his own behalf. The Supreme Court denied the petition and affirmed the Commission.

Facts

De Guia entered government service in March 1956 as a storekeeper in the Bureau of Internal Revenue. Over the years he was promoted several times, becoming a Senior Revenue Examiner in December 1977 and, in August 1985, a Supervising Revenue Enforcement Officer. He held that last position until disability forced him to retire at the age of sixty-one in January 1988.

Sometime in 1982 he experienced loss of vision and consulted an eye specialist, who diagnosed his impairment as the result of continuous visual insult in the pursuit of his duties, with cataract and vitreous hemorrhage setting in as complications of both eyes. Laser photocoagulation was prescribed and performed in 1983 by a specialist of the Eye Referral Center, who found him suffering from proliferative diabetic retinopathy with vitreous hemorrhage. In August 1986 he underwent panretinal photocoagulation at an eye center in North Carolina.

In June 1987 he filed his claim for compensation benefits. The Government Service Insurance System denied it, and the Employees' Compensation Commission affirmed, finding no causal relation between his diabetes mellitus and his employment. Before the Supreme Court he argued that his long hours examining voluminous income tax returns subjected him to constant physical and mental stress, and that under the Millora case such stresses are medically recognized as predisposing factors in the development of diabetes. The Court found that he had in fact been suffering from diabetes for twenty-five years, meaning even before he became a Revenue Examiner.

Issues

• Whether or not an employee claiming sickness benefits for an illness not listed as an occupational disease must prove that the risk of contracting the disease is increased by his working conditions.
• Whether or not de Guia discharged that burden of proof for his diabetic retinopathy and his underlying diabetes mellitus.
• Whether or not the Millora ruling on physical and emotional stress as a predisposing factor to diabetes applies to his case.

Applicable Provisions

The Court states the governing rule of the Labor Code on sickness benefits:

Under the Labor Code, in order that an employee may be entitled to sickness benefits, they must have resulted from any illness (a) definitely accepted as an occupational disease, or (b) caused by employment, subject to proof that the risk of contracting the same is increased by working conditions.

This is the test the Court applies: since de Guia's ailments are not listed occupational diseases, he falls under the second branch and must prove that his working conditions increased the risk.

The Court also relies on the Table of Occupational Diseases in Annex A of the Rules on Employees' Compensation, noting that neither diabetic retinopathy nor diabetes mellitus appears in it. That omission is what shifts the burden of proof onto the claimant.

Ruling

On the first issue, the Court held that because diabetic retinopathy and its underlying ailment, diabetes mellitus, are not listed in the Table of Occupational Diseases, the petitioner was required to prove a positive proposition, namely, that the risk of contracting the disease is increased by working conditions. The Court cited its earlier ruling in Rodriguez versus Employees' Compensation Commission for this burden.

On the second issue, the Court held that the burden was not discharged. Diabetic retinopathy is a complication linked with the diabetic condition, and the very medical terminology emphasizes that it is a complication. The eye condition was not contracted by reason of employment but arose as a complication of an underlying disease, and irrespective of his working conditions the complication could have set in. Diabetes mellitus itself is a metabolic and familial disease to which one is predisposed by heredity, obesity, or old age. Even assuming he proved he was not predisposed by heredity, he did not show he was not predisposed by old age or obesity. The 1982 medical certificate, the Court observed, carefully avoided any mention of the cause of the complications, which was the diabetic condition.

On the third issue, the Court distinguished Millora. There, stress was accepted as a predisposing factor because it was shown that the claimant was not predisposed to diabetes by reason of old age, obesity, or heredity. Similar proof was wanting here, since de Guia had been suffering from diabetes for no less than twenty-five years, even before he became a Revenue Examiner and was allegedly subjected to stress.

Doctrine

For an employee to be entitled to sickness benefits, the illness must either be a definitely accepted occupational disease, or be caused by employment with proof that the risk of contracting it is increased by working conditions. Where the ailment is not in the Table of Occupational Diseases, the claimant bears the burden of proving, as a positive proposition, that the risk of contracting the disease is increased by his working conditions. A complication of a personal, pre-existing disease is not compensable where it is not shown that the employment increased the risk, since the complication could have set in regardless of working conditions. Stress as a predisposing factor, as recognized in Millora, applies only where the claimant first shows he was not predisposed to the disease by old age, obesity, or heredity.

Disposition

The Supreme Court denied the petition and affirmed the decision of the Employees' Compensation Commission, without costs.

Remember This

Memorize the two-branch test: an occupational disease, or an illness caused by employment with proof that the risk is increased by working conditions, and the burden of that proof rests on the claimant for unlisted ailments. Examiners use this case to test the non-compensability of a complication of a personal disease and to distinguish the Millora stress ruling.