Roma, 23 aprile 2021 – Con Sentenza n. 63 del 13 aprile scorso, la Corte costituzionale si è espressa in materia di criteri di calcolo del danno biologico da infortunio sul lavoro o malattia professionale, in presenza di preesistenti menomazioni.
La questione di legittimità costituzionale è stata sollevata esaminando il caso relativo ad un lavoratore, titolare di una rendita INAIL per una malattia professionale denunciata prima del Dlgs 38/2000 che aveva successivamente contratto una nuova tecnopatia, ricadente nel nuovo regime ed insistente sullo stesso organo.
Si trattava dunque di individuare lo strumento attraverso cui poter correttamente valutare, alla luce della disciplina vigente, i due danni, considerando che entrambi erano riconducibili al lavoro, insistevano sullo stesso organo ma ricadevano su due regimi completamente differenti.
La questione, certamente di natura tecnica e su cui ci si riserva di approfondire può essere riassunta come segue.
La norma oggetto di esame della corte è l’articolo 13, comma 6, del D.lgs. 38/2000 il quale stabilisce, al primo periodo, che il grado di menomazione dell’integrità psicofisica causato da infortunio sul lavoro o malattia professionale, quando risulti aggravato da menomazioni preesistenti derivanti da fatti estranei al lavoro o da infortuni o malattie professionali verificatisi o denunciate prima della data di entrata in vigore del decreto ministeriale di cui al comma 3 del decreto stesso e non indennizzati in rendita, deve essere rapportato non all’integrità psicofisica completa, ma a quella ridotta per effetto delle preesistenti menomazioni.
In sostanza se un lavoratore ha una preesistenza extra lavorativa (ad esempio un danno alla gamba a causa di un infortunio domestico) e subisce un infortunio sul lavoro con compromissione della stessa gamba, il secondo danno deve essere quantificato prendendo in considerazione anche il primo, attraverso la nota formula matematica che viene definita “formula Gabrielli”.
Il secondo periodo tuttavia, quello oggetto dell’eccezione di legittimità costituzionale, dispone che, quando per le conseguenze degli infortuni o delle malattie professionali verificatisi o denunciate prima della data di entrata in vigore del decreto ministeriale di cui al comma 3 l’assicurato percepisca una rendita o sia stato liquidato in capitale ai sensi del Testo Unico, il grado di menomazione conseguente al nuovo evento infortunistico viene valutato senza tenere conto delle preesistenze. Pertanto in tale caso l’assicurato continuerà a percepire anche l’eventuale rendita corrisposta in conseguenza di infortuni o malattie professionali verificatisi o denunciate prima della data sopra indicata.
Secondo la Corte, pertanto, l’assicurato che ha già avuto dall’INAIL un indennizzo per la prima tecnopatia, otterrebbe di più, nella stima degli effetti pregiudizievoli derivanti dalla seconda tecnopatia concorrente, del lavoratore che – in base al TU Infortuni – non avesse ricevuto alcun precedente indennizzo.
Appare dunque evidente il diverso sistema valutativo utilizzato nel primo periodo e nel secondo: in sostanza se le preesistenze sono extra lavorative vengono considerate, mentre se la preesistenza fosse di natura lavorativa (e sia titolare per la stessa di una rendita) non bisognerebbe tenerne conto.
Secondo la Corte Costituzione dunque l’articolo 13, comma 6, secondo periodo, del Dlgs n. 38/2000, è quindi in contrasto con l’articolo 3 della Costituzione nella parte in cui non prevede che il grado di menomazione dell’integrità psicofisica causato da infortunio sul lavoro o malattia professionale, quando risulti aggravato da menomazioni preesistenti concorrenti deve essere rapportato non all’integrità psicofisica completa, ma a quella ridotta per effetto delle preesistenti menomazioni, secondo quanto dispone il primo periodo del comma 6 dell’articolo 13 Dlgs n. 38 del 2000.
Il medico legale dovrà quindi differenziare, nell’ambito delle due patologie, il danno biologico riconducibile alla preesistenza, così da abbattere il valore dell’integrità psicofisica su cui si riverbera la patologia concorrente, che vedrà quindi maggiormente considerati i suoi effetti pregiudizievoli e la relativa stima.
Visto e considerata la pronuncia di illegittimità costituzione della norma, la stessa non potrà essere più applicata con efficacia ex tunc dal giorno successivo alla pubblicazione della sentenza.
Criteri di valutazione delle malattie preesistenti A cura dell'Ufficio Servizi Istituzionali e Legali
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