GR 146891; (July, 2002) (Digest)
G.R. No. 146891 ; July 30, 2002
RUBEN T. LIMBO, petitioner, vs. EMPLOYEES COMPENSATION COMMISSION and SOCIAL SECURITY SYSTEM, respondents.
FACTS
Petitioner Ruben T. Limbo worked for Nestlé Philippines, Inc. from 1966 to 1996, eventually as an Area Sales Supervisor. In December 1994, he was hospitalized and diagnosed with chronic renal disease, leading to a kidney transplant in January 1995. He filed a claim for compensation benefits under P.D. No. 626, as amended, but the Social Security System (SSS) denied it, stating his “end-stage renal disease secondary to uric acid nephropathy” had no causal relation to his job. The Employees Compensation Commission (ECC) affirmed the denial, a decision subsequently upheld by the Court of Appeals.
ISSUE
Whether Limbo’s end-stage renal disease secondary to uric acid nephropathy is compensable under P.D. No. 626, as amended.
RULING
Yes, the disease is compensable. While the illness is not listed as an occupational disease under the Amended Rules, a claim remains viable if the claimant proves the risk of contracting the disease was increased by his working conditions. The Court found Limbo successfully established this work-connection. His job involved significant responsibility for sales, collections, and managing personnel across multiple provinces, a workload likely to induce stress and hypertension. Critically, his attending nephrologist, Dr. Agnes D. Mejia, provided a medical abstract stating that Limbo had a long history of hypertension and gout, and that “the stress at work could have aggravated his condition,” leading to complications like hypertensive nephrosclerosis and eventual renal failure. The Court emphasized that a physician’s report constitutes the best evidence of work-connection and can be the basis for an award. Applying the principle that probability, not certainty, is the touchstone for compensability, and that a reasonable work connection suffices, the Court reversed the appellate court’s decision and ordered the SSS to grant Limbo’s compensation benefits.