GR L 46684; (April, 1988) (Digest)
G.R. No. L-46684 April 27, 1988
ROSALINA G. NAVALTA, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM, BUREAU OF CUSTOMS and EMPLOYEES’ COMPENSATION COMMISSION, respondents.
FACTS
Alberto Navalta, a Port Administration Checker for the Bureau of Customs, was assigned to assist in inventorying properties in a warehouse in August 1976. During this assignment, he suddenly experienced extreme abdominal pain, leading to his confinement at the Philippine General Hospital. He died on September 8, 1976, and the cause of death was determined to be Cancer of the Pancreas. His widow, Rosalina Navalta, filed a claim for income benefits under the Employees’ Compensation Act.
The Government Service Insurance System (GSIS) denied the claim, finding that pancreatic cancer is not a listed occupational disease. The Employees’ Compensation Commission (ECC) affirmed this denial. The petitioner then elevated the case to the Supreme Court via a petition for review on certiorari.
ISSUE
Whether the death of Alberto Navalta due to Cancer of the Pancreas is compensable under the Employees’ Compensation Act.
RULING
The Supreme Court dismissed the petition and affirmed the decisions of the GSIS and ECC. The legal logic is anchored on the distinction between listed occupational diseases and other illnesses under the compensation law. Since Cancer of the Pancreas is not an occupational disease listed by the ECC, the burden of proof shifted to the claimant to establish that the deceased’s working conditions increased the risk of contracting the ailment. The petitioner failed to discharge this burden.
The Court, citing medical authority, noted that pancreatic carcinoma’s etiology is generally unknown, with predisposing factors being age, sex, genetic influence, diabetes mellitus, and smoking—not specific occupational exposures. The petitioner’s argument that exposure to warehouse chemicals like alphanaphtylamine caused the cancer was unsubstantiated. The Court clarified that such chemicals are associated with cancer of the bladder, a listed disease, but the deceased’s bladder was affected only by metastatic spread from the primary pancreatic cancer. The direct cause remained pancreatic cancer, for which no work-connection was proven. Thus, compensation was correctly denied, as the fatal illness was not shown to be work-related or an increased risk of his employment.