GR 121545; (November, 1996) (Digest)
G.R. No. 121545 November 14, 1996
EMPLOYEES’ COMPENSATION COMMISSION (ECC) and GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), petitioners, vs. COURT OF APPEALS and LILIA S. ARREOLA, respondents.
FACTS
Lilia S. Arreola, an Engineer II at the National Bureau of Investigation (NBI), performed duties involving research, instrumental analysis of drugs and poisons, attendance to field cases, taking paraffin casts at the morgue, and assisting in field investigations. In May 1993, she was diagnosed with ureterolithiasis (kidney stones in the ureter) and underwent surgery. She filed a claim for compensation benefits under P.D. No. 626, as amended.
The GSIS and subsequently the ECC denied her claim. They ruled that ureterolithiasis is not a listed occupational disease and that Arreola failed to prove that her work increased the risk of contracting it. The ECC cited medical authority stating that urinary stones arise from a breakdown in the body’s balance between conserving water and excreting materials of low solubility, influenced by diet and activity.
ISSUE
Did the Court of Appeals err in holding that the nature of Arreola’s work increased the risk of contracting ureterolithiasis, making it compensable?
RULING
No, the Court of Appeals did not err. The Supreme Court affirmed its decision. Under the employees’ compensation law, for a non-listed disease like ureterolithiasis to be compensable, the claimant must show by substantial evidence that the risk of contracting the illness was increased by the working conditions. The Court agreed with the appellate court’s factual finding that the exigencies of Arreola’s work as an NBI engineer—which demanded intense concentration, involved stress and pressure, and likely required her to forego urination to maintain focus during lengthy analytical procedures—increased the risk of developing kidney stones.
The Court emphasized the principle of liberality in construing social legislation in favor of the worker. It held that the appellate court’s conclusion was sufficiently grounded on the nature of the described duties and common human experience, constituting substantial evidence. However, the awarded amount was reduced to P12,619.00, as only the hospital and doctor’s fees were substantiated by evidence, excluding claims for X-ray, laboratory, and medicine expenses.