G.R. No. L-59760 May 19, 1984
BENIGNO C. GASCON, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION; GOVERNMENT SERVICE INSURANCE SYSTEM and THE BUREAU OF CUSTOMS, respondents.

FACTS

Petitioner Benigno C. Gascon served as a customs examiner in the Bureau of Customs for twenty-six years. His duties involved examining passenger baggage and cargo, often in poorly ventilated warehouses with dust and toxic substances, and working irregular hours, including overnight shifts for delayed flights. Due to contracting diabetes mellitus and pulmonary tuberculosis, he incurred prolonged absences and eventually retired on April 1, 1975. He filed a claim for disability benefits with the GSIS on February 9, 1976, attributing his illnesses to the nature and conditions of his employment.
The GSIS denied the claim, stating the ailments were contracted prior to the effectivity of the new Employees’ Compensation Program under Presidential Decree No. 626. The Employees’ Compensation Commission affirmed the denial, citing two grounds: first, the claim was filed after the March 31, 1975 deadline for claims accruing before the New Labor Code under its Article 292; and second, the Commission lacked jurisdiction as the claim was governed by the old Workmen’s Compensation Act.

ISSUE

Whether the Employees’ Compensation Commission erred in denying petitioner’s claim based on prescription and lack of jurisdiction.

RULING

Yes, the Supreme Court reversed the Commission’s decision. The legal logic is anchored on the applicable law governing the accrual of the claim and the Commission’s jurisdictional authority. Petitioner’s illnesses, particularly his advanced pulmonary tuberculosis in 1974, commenced and were contracted prior to January 1, 1975, the effectivity date of the New Labor Code’s compensation provisions. Consequently, his claim is governed by the Workmen’s Compensation Act, not Presidential Decree No. 626.
Under established precedents like Corales v. ECC and Santarin v. ECC, the ten-year prescriptive period for claims under the Workmen’s Compensation Act applies, not the March 31, 1975 deadline in Article 292 of the New Labor Code. Since petitioner’s right accrued in 1974 and he filed in 1976, his claim was well within the ten-year period and not time-barred. Furthermore, the Commission, as the successor of the defunct Workmen’s Compensation Commission, has jurisdiction to adjudicate such claims and is duty-bound to apply the principles of the old law, including the presumption of compensability and aggravation.
The Court found that the nature of petitioner’s duties—exposure to health risks, dust, irregular hours, and abrupt temperature changes—increased the risk of contracting tuberculosis. The employer failed to rebut the statutory presumption that the illness arose from or was aggravated by employment. Therefore, the claim is compensable. The Bureau of Customs was ordered to pay disability benefits, reimburse medical expenses, and pay attorney’s fees.