G.R. No. L-63860 April 24, 1984
Nemia Sagliba, petitioner, vs. Employees’ Compensation Commission, Government Service Insurance System (Bureau of Agricultural Economics), respondents.

FACTS

Diosdado Sagliba worked as a senior statistician for the Bureau of Agricultural Economics from 1969 until his death in 1981. In early 1981, he exhibited symptoms including weakness, anorexia, and fatigue, later experiencing gastrointestinal bleeding. Admitted to Capitol Medical Center on April 27, 1981, he was diagnosed with hepatoma (liver carcinoma), bleeding varices, malnutrition, sepsis, and hepatic coma. He died from hepatic failure on May 7, 1981, at age 37.
His widow, petitioner Nemia Sagliba, filed a claim for death benefits under P.D. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, asserting the fatal hepatoma was not work-connected. The Employees’ Compensation Commission (ECC) affirmed the denial, prompting this petition for review.

ISSUE

Whether the fatal ailment, hepatoma, is compensable as work-connected under P.D. 626, as amended.

RULING

The Supreme Court ruled in favor of the petitioner, granting compensation. The legal logic centered on the application of the “increased risk” theory under the governing law. For a non-listed illness like hepatoma to be compensable, Section 1(b), Rule III of the implementing rules requires proof that the risk of contracting the disease was increased by the working conditions. The Court found this standard met.
The Court rejected the respondents’ rigid stance, noting that medical authorities acknowledged the cause of hepatoma as unknown, with potential factors including chemical irritants and dietary deficiencies. The deceased’s work as a statistician in agricultural economics could have involved exposure to various environmental factors. Citing precedent (Neri vs. ECC), the Court emphasized that when the etiology of a disease is uncertain, a sweeping conclusion that it is not work-related is untenable. It is sufficient that employment contributed, even in a small degree, to the development of the disease.
Furthermore, the Court highlighted the liberal interpretation mandated in labor legislation. Applying Article 4 of the Labor Code, all doubts in implementation should be resolved in favor of labor. The degree of proof required is merely substantial evidence, not direct causal relation, and the strict rules of evidence do not apply. The Court found a reasonable work-connection was established, warranting compensation. The GSIS was ordered to pay death benefits, reimburse medical expenses, and cover funeral costs and attorney’s fees.