GR 126352; (September, 2001) (Digest)
G.R. No. 126352 ; September 7, 2001
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), petitioner, vs. COURT OF APPEALS and GLORIA A. BARRAMEDA, respondents.
FACTS
Respondent Gloria A. Barrameda was a Clerk III at the Sandiganbayan. Her duties included filing and retrieving voluminous case records from old, rusty steel cabinets. On August 26, 1992, while pushing a jammed cabinet drawer, she felt excruciating pain in her wrists. Her condition was later diagnosed as bilateral tendonitis. She filed a claim for compensation benefits with the GSIS under P.D. No. 626.
The GSIS and subsequently the Employees’ Compensation Commission (ECC) denied her claim. They ruled that tendonitis is not a listed occupational disease and that Barrameda failed to prove her work increased the risk of contracting it. The ECC also noted she sought medical help a month after the incident. The Court of Appeals reversed these rulings, finding substantial evidence that her work caused the ailment and ordering the GSIS to pay the compensable amount.
ISSUE
Whether Gloria A. Barrameda is entitled to compensation benefits for a work-related ailment under P.D. No. 626.
RULING
Yes. The Supreme Court affirmed the Court of Appeals’ decision. For a non-listed ailment like tendonitis, the claimant must prove by substantial evidence that the risk of contracting the illness was increased by the working conditions. Substantial evidence is that relevant evidence which a reasonable mind might accept as adequate to support a conclusion.
The Court found such substantial evidence present. Barrameda’s functions—repetitively opening, closing, pushing, and pulling heavy, jammed cabinet drawers while handling voluminous files—reasonably caused strain and overstretching of her wrist tendons. The affidavits of her officemates corroborated the incident. The law only requires reasonable proof of work-connection, not direct or absolute proof. To demand more would contravene the social justice principle and the liberal interpretation of compensation laws in favor of laborers. Thus, her ailment is compensable.