Week 4 Coverage Table
The table below mirrors the workbook's assigned cases for Week 4 and links each item to its digest page.
Class. records how the case actually stands to the subtopic it was assigned under — DIRECT (the Court squarely applies the doctrine), ANALOGOUS (it decides the point under a different provision or doctrine), REJECTED (the Court found the doctrine not established), INCIDENTAL (the doctrine is mentioned but the disposition rests elsewhere). Reciting a REJECTED case as if it were DIRECT inverts the holding.
| # | Assigned Case | Topic/Subtopic | Class. | Digest |
|---|---|---|---|---|
| 1 | Bejerano v. ECC, G.R. No. 84777, January 30, 1992 | 3 — Disability and death benefits under the Labor Code (Arts. 197-199; ECC Rules) | DIRECT | |
| 2 | Vicente v. ECC, G.R. No. 85024, January 23, 1991 | 3 — Disability and death benefits under the Labor Code (Arts. 197-199; ECC Rules) | DIRECT | |
| 3 | Tolosa v. ECC, G.R. No. L-60509, May 8, 1985 | 3 — Disability and death benefits under the Labor Code (Arts. 197-199; ECC Rules) | DIRECT | |
| 4 | Manuzon v. ECC, G.R. No. 88573, June 25, 1990 | 3 — Disability and death benefits under the Labor Code (Arts. 197-199; ECC Rules) | DIRECT |
Citation defects in the workbook list. Item 4 — the petitioner is Manuzon, not "Manauzon"; the digest keeps the workbook spelling in its filename so the link stays stable, and notes the correct caption. Item 3 — Tolosa's docket carries the L- prefix: G.R. No. L-60509.
On the renumbering. The syllabus heading uses the current numbers, Arts. 197-199; all four decisions predate DOLE Department Advisory No. 01, s. 2015 and cite the old Arts. 191-193, with Manuzon citing old Art. 194(b) (now Art. 200[b]) for death benefits. Quote the old numbers as the Court used them and give the new ones alongside.
Recitation Map
One line per case — what it is for, and the categorical holding.
| Case | What it is for | Categorical holding |
|---|---|---|
| Bejerano v. ECC | Whether disability is measured medically or by lost earning capacity | By earning capacity — the physician's certification plus a disability-forced retirement establishes permanent total disability |
| Vicente v. ECC | The dividing line between permanent total and permanent partial disability | Inability to perform one's customary work for more than 120 days is permanent total disability "regardless of whether or not he loses the use of any part of his body" |
| Tolosa v. ECC | Percentage-of-impairment tables against actual incapacity to work | Permanent total disability "does not mean an absolute helplessness"; compelled early retirement is itself proof — but death nine years later drew no death benefits |
| Manuzon v. ECC | Whether a retiree remains a "covered employee" for death benefits | He does — where the ailment causing the compensable disability is closely related to the one causing death, the lapse of years and a different medical label do not defeat the claim |
Study Notes
All four cases fight the same battle, and the ECC loses it every time. The Commission's recurring premise — that "disability should be understood more on its medical significance rather than loss of earning capacity" — is rejected in Bejerano in terms, and rejected in substance in Vicente and Tolosa. The operative question is never how severe the ailment looks on a percentage table but whether the employee can still pursue the work he was doing. Tolosa states the consequence most memorably: permanent total disability "does not mean an absolute helplessness."
Two proofs recur, and both are cheap to state in recitation. First, the attending physician's certification of permanent total disability, which the Court in Bejerano and Vicente treats as sufficient against the GSIS's contrary evaluation. Second, retirement compelled by the ailment — in Tolosa the Court treats a forced early retirement as itself proof of total disablement. Add the codal marker from Vicente: inability to perform the customary job for more than 120 days, where Rule X does not otherwise apply.
Where the line does fall against the claimant. Tolosa awarded disability compensation and still denied the widow death benefits, because death came almost nine years after the disability. Manuzon is the counterpoint and the more generous rule: a retiree who was retired because of permanent total disability remains a covered employee under old Art. 194(b) (now Art. 200[b]), and where the ailment that caused the disability is closely related to the ailment that caused death, four and a half years and a different medical label — cerebrovascular accident, then myocardial infarction — do not break the chain. Reciting the two together is how to state the rule and its limit in one breath.
What the week's outline still expects beyond the cases. The four ECC cases cover only item 3. The SSS and GSIS laws, the Portability Law, seafarers' claims under the 2010 POEA-SEC and R.A. No. 12021, and Labor Advisory No. 19 on workplace mental health carry no assigned case and are recitation-and-reading items.