G.R. No. L-47294. April 8, 1987.
Hilaria Dabatian, petitioner, vs. Government Service Insurance System (General Services Department, Cagayan de Oro City), respondent.

FACTS

Sigfredo A. Dabatian, a garbage truck driver for the Cagayan de Oro City government working night shifts, collapsed on duty and died two weeks later on July 3, 1976, from a bleeding peptic ulcer. His widow, Hilaria Dabatian, filed a claim for death benefits under the Employees’ Compensation Program. The Government Service Insurance System (GSIS) denied the claim, ruling that peptic ulcer is not a listed occupational disease and that no evidence showed the employment increased the risk of contracting it. The Employees’ Compensation Commission (ECC) affirmed the denial, noting medical authorities attribute peptic ulcer to factors like heavy coffee consumption, smoking, and hereditary predisposition. The ECC found the deceased was a heavy coffee drinker to ward off sleepiness but concluded this aggravation was not work-connected compensation under the governing law.
The case reached the Supreme Court via a petition for review. The procedural history includes an initial denial for failure to pay docket fees, subsequently reconsidered to allow the petitioner to litigate as a pauper. The ECC and GSIS filed their memoranda, but the petitioner failed to submit hers.

ISSUE

Whether the death of Sigfredo A. Dabatian, resulting from a peptic ulcer, is compensable under the applicable employees’ compensation law.

RULING

The Supreme Court denied the petition, upholding the denial of compensation benefits. The legal logic centers on the applicable law and the burden of proof. The death occurred on July 3, 1976, which is after the effectivity of the New Labor Code (Presidential Decree No. 442, as amended). This abrogated the old Workmen’s Compensation Act. The Court found no evidence the ailment was contracted prior to January 1, 1975, which would have invoked the more liberal provisions of the old law.
Under the present law, for an illness like peptic ulcer—which is not listed as an occupational disease by the ECC—the claimant must prove that the risk of contracting the disease was increased by the employee’s working conditions. The Court noted the petitioner failed to present any competent evidence to establish this causal link. While the deceased’s heavy coffee drinking, a habit linked to his night-shift work, may have aggravated his condition, the Court emphasized that the principle of aggravation is no longer a ground for compensation under the New Labor Code. The legislative intent was to restore a balance between employer and employee by abolishing the previous presumptions of compensability. The conditions of night-shift work and coffee consumption were not deemed peculiar risks significantly increasing the probability of peptic ulcer beyond what is common to many other employments. Therefore, the claim lacked merit.