GR 87590; (November, 1991) (Digest)
G.R. No. 87590 November 12, 1991
PURIFICACION R. QUIZON, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION, GOVERNMENT SERVICE INSURASE SYSTEM, and PHILIPPINE AIR FORCE, respondents.
FACTS
Petitioner Purificacion Quizon, mother of deceased Technical Sergeant Rolando Quizon of the Philippine Air Force, sought death benefits under P.D. 626. Rolando, on continuous active duty since 1967, was admitted to a military hospital on July 15, 1986, after being found unable to speak, stand, or walk. He died two days later. The attending physician, Maj. Jose del Rosario, prepared a Clinical History stating the cause of death as “Cardio-Pulmonary Arrest secondary to cerebro-vascular accident (CVA).” Based on this, petitioner filed her claim with the GSIS.
The GSIS denied the claim, citing a lack of conclusive proof that Rolando died of CVA, noting an absence of a history of hypertension, prior treatment, or an ECG. The ECC affirmed the denial, adding that the deceased’s alleged drinking the night before his confinement aggravated his condition, thus removing the claim from the purview of the compensation law. Petitioner argued that the official medical finding of CVA, a listed occupational disease, was being disregarded without basis.
ISSUE
Whether the Employees’ Compensation Commission committed grave abuse of discretion in denying the claim for death benefits.
RULING
Yes. The Supreme Court set aside the decisions of the GSIS and ECC and remanded the case for further proceedings. The legal logic is twofold. First, the Court found a denial of due process. The GSIS acted with undue haste, denying the claim based solely on a cursory evaluation of the clinical history without affording the petitioner an opportunity to submit additional evidence or be heard. This was compounded by the ECC’s unsupported conclusion that alcohol aggravated the death—an attribution based merely on an allegation from fellow soldiers, not on medical proof, which unfairly prejudiced the claim.
Second, while the Court acknowledged that for a listed occupational disease like CVA to be compensable, the claimant must prove the concurrence of conditions set in the rules, it emphasized the constitutional policy of compassion for labor. Given the official medical certification of death due to CVA, a compensable illness, justice demanded that petitioner be allowed to present evidence to establish these conditions. The respondents’ cavalier dismissal, without a hearing, violated fundamental fairness. Thus, the case was remanded to the ECC for the reception of petitioner’s evidence.