G.R. No. 84415 June 29, 1989
DIONISIA C. SANTE, in representation of her deceased husband SEVERINO T. SANTE, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION, respondent.

FACTS

Severino T. Sante, a driver for the Ministry of Public Works and Highways, was diagnosed with amyotrophic lateral sclerosis (ALS) in 1981. His condition, involving progressive muscular weakening and difficulty in breathing and swallowing, forced his retirement. He filed a claim for disability benefits under P.D. No. 626, but the GSIS denied it, ruling ALS was not a listed occupational disease for a driver and that Sante failed to prove his working conditions increased the risk of contracting it. The ECC affirmed this denial. Severino Sante died in 1984, and his widow, Dionisia, continued the claim. She invoked the Supreme Court’s ruling in Mercado, Jr. v. ECC, which held that for diseases of unknown origin, the claimant need not prove work-connection. The GSIS and ECC maintained their position, leading Dionisia to file this Petition for Certiorari instead of submitting additional evidence as directed.

ISSUE

Whether the petitioner is required to prove that her late husband’s illness, amyotrophic lateral sclerosis, was caused or aggravated by his working conditions as a driver, notwithstanding that the disease’s cause is medically unknown.

RULING

The petition is denied. The Court, through Justice Feliciano, held that the petitioner has the duty to establish work-connection. The legal logic is anchored on the explicit provisions of P.D. No. 626, as amended, which established a state insurance fund with a no-fault liability system but limited compensability. For a sickness and resulting disability or death to be compensable, the law requires that it must be an “occupational disease” listed by the ECC, or the claimant must prove that the risk of contracting the disease was increased by the employee’s working conditions. ALS is not a listed occupational disease. The Court explicitly overruled its prior decisions in Mercado, Jr. and Nemaria v. ECC, which had dispensed with the requirement of proving work-connection for diseases of unknown etiology. These were reversed by the controlling precedent in Raro v. ECC, which reinstated the statutory imperative that the claimant bears the burden of proof to show either causation or aggravation by work conditions. The Court clarified that this proof need not be direct or scientific certainty but must constitute real and substantial evidence providing a reasonable basis for the conclusion. Since the petitioner did not present such evidence to the GSIS, the denial of the claim was proper. However, the Court, in line with equity, affirmed the denial without prejudice, allowing the petitioner another opportunity to present before the GSIS any evidence she may have to demonstrate work-connection or aggravation.