G.R. No. L-55233 November 29, 1988
CRISPULO GAROL, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (Ministry of Health), respondents.

FACTS

Emeteria Garol, a midwife for the Ministry of Health for twenty-nine years, was last assigned to a remote area in Quezon Province. In October 1978, she exhibited symptoms of jaundice. She was hospitalized in January 1979 and diagnosed with liver cirrhosis. Despite treatment, her condition deteriorated, leading to her death from hepatic failure due to liver cirrhosis in a Manila hospital. Her surviving spouse, Crispulo Garol, filed a claim for death benefits under P.D. No. 626, as amended (the Labor Code), contending that her illness and death were caused by the conditions of her employment.
The Government Service Insurance System (GSIS) denied the claim, ruling that cirrhosis of the liver is not an occupational disease characteristic of her employment as a midwife. The Employees’ Compensation Commission (ECC) affirmed the GSIS decision. The petitioner elevated the case to the Supreme Court, arguing that the illness, having been contracted during employment, should be presumed compensable.

ISSUE

Whether the death of Emeteria Garol, caused by liver cirrhosis, is compensable under the provisions of P.D. No. 626, as amended.

RULING

The Supreme Court denied the petition and affirmed the ECC decision, ruling that the death was not compensable. The legal framework under the Labor Code, which governs as the illness manifested after January 1, 1975, requires the claimant to prove compensability. Under Article 167(1) and the implementing rules, for a sickness to be compensable, it must either be listed as an occupational disease in Annex “A” of the Amended Rules, or the employee must prove that the risk of contracting the illness was increased by the working conditions.
The Court held that liver cirrhosis is not listed as an occupational disease under Annex “A”. Therefore, the burden shifted to the petitioner to demonstrate that the conditions of his wife’s employment increased the risk of contracting the ailment. The Court found that the petitioner failed to discharge this burden. The mere fact that the illness manifested during employment does not, under the present law, give rise to a presumption of compensability, as the old presumption under the prior Workmen’s Compensation Act was expressly discarded by the Labor Code.
Furthermore, the Court noted the ECC’s finding, based on hospital records, that the deceased had a history of alcoholism—a known major factor in the development of liver cirrhosis. This uncontroverted evidence supported the conclusion that her ailment was not work-related but was attributable to personal habit. Consequently, without substantial proof linking the illness to her employment conditions, the claim for death benefits was correctly denied.