G.R. No. 128523 September 28, 1998
GOVERNMENT SERVICE INSURANCE SYSTEM, petitioner, vs. COURT OF APPEALS and ZENAIDA LIWANAG, respondents.

FACTS

Private respondent Zenaida Liwanag is the surviving spouse of the late Police Senior Superintendent Jaime Liwanag, who died on September 14, 1994 at age 48 after 17 years of continuous service in the police force. The cause of death was Upper GI Bleeding, Cirrhosis Secondary to Hepatitis B; Hepatocellular Carcinoma. He was admitted on August 28, 1994, with a CT scan showing Cirrhosis with probable Hepatocellular CA, HB 5A3 positive. Zenaida Liwanag filed a claim for compensation benefits with the GSIS under P.D. No. 626, as amended. The GSIS denied the claim, stating the ailments were not an occupational disease under the law and the risk of contracting them was not increased by his employment as a policeman. The Employees’ Compensation Commission (ECC) affirmed the GSIS ruling, finding no causal relation between the ailments and his employment, noting the diseases are not inherent among policemen and everyone is susceptible to them. The Court of Appeals reversed the ECC and granted the claim, relying on two PNP documents: an “Investigation Report” which concluded his death was in line of duty and it was “highly believed” he acquired the illness in the course of employment since some office personnel were Hepatitis B positive; and a “Report of Proceedings of LOD Board” where a member stated it was “highly possible” he got infected recently in his Directorate and that Hepatitis B was endemic in the camp. The CA applied the principle of liberal interpretation for social legislation.

ISSUE

Whether the Court of Appeals erred in granting compensation benefits to Zenaida Liwanag by finding a causal connection between the deceased’s ailments (Cirrhosis secondary to Hepatitis B and Hepatocellular Carcinoma) and his employment as a police officer, based on the presented PNP documents and a liberal interpretation of the law.

RULING

Yes, the Court of Appeals erred. The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the decision of the Court of Appeals, and REINSTATED the decision of the Employees’ Compensation Commission denying the claim.
The governing law is P.D. No. 626, as amended, which requires that for a sickness and resulting death to be compensable, the sickness must be a result of an occupational disease listed under the rules with the conditions satisfied, or proof must be shown that the risk of contracting the disease is increased by the working conditions. The ailments of the deceased are not listed as occupational diseases. Therefore, the claimant must prove by substantial evidence that the risk of contracting the disease was increased by the deceased’s working conditions. The two PNP documents relied upon by the Court of Appeals do not constitute the required substantial evidence. They contain speculative and conjectural statements such as “highly believed,” “highly possible,” and “strongly believe,” which are insufficient to establish a causal link. The medical findings in the records did not indicate how his work as a police officer increased the risk of contracting Hepatitis B, which can be transmitted through various means unrelated to employment. The principle of liberal interpretation in social legislation applies to the law’s implementation and interpretation, not to the evidence required. It cannot relieve the claimant of the burden of proving a causal connection by substantial evidence, which was not met. The findings of the ECC, a specialized quasi-judicial agency, are accorded respect and finality in the absence of grave abuse of discretion.