G.R. No. 148089 March 24, 2006
JAIME M. BARRIOS, substituted by his heirs, ERLINDA BARRIOS and CHRISTIANNE JOY BARRIOS, Petitioners, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (NATIONAL IRRIGATION ADMINISTRATION), Respondents.

FACTS

Jaime M. Barrios, a driver-mechanic for the National Irrigation Administration (NIA), retired in January 1997 after 22 years of service. Months before his retirement, he was hospitalized for chronic renal failure and diabetes mellitus, from which he had suffered for fifteen years. He eventually died in January 1998 due to renal failure secondary to diabetes mellitus. His heirs filed a claim for death benefits under Presidential Decree No. 626, as amended.
The Government Service Insurance System (GSIS) and, on appeal, the Employees’ Compensation Commission (ECC) denied the claim. They ruled that end-stage renal disease and diabetic nephropathy are not listed as occupational diseases, and the claimants failed to prove that Barrios’s working conditions increased the risk of contracting these ailments. The Court of Appeals affirmed this denial, distinguishing Barrios’s case from the precedent in Narazo v. ECC, which granted compensation to an employee whose work conditions aggravated his urinary tract infection leading to renal failure.

ISSUE

Whether the heirs of Jaime Barrios are entitled to compensation benefits under P.D. No. 626, as amended, for his death resulting from renal failure secondary to diabetes mellitus.

RULING

Yes, the petitioners are entitled to compensation benefits. The Supreme Court reversed the Court of Appeals, applying a liberal interpretation in favor of the employee, as mandated by the Constitution’s policy to protect labor. Under the implementing rules of P.D. No. 626, for a non-listed disease like Barrios’s to be compensable, proof must be shown that the risk of contracting the disease is increased by the working conditions.
The Court found a reasonable basis to conclude that Barrios’s work as a driver-mechanic aggravated his condition. Medical authorities establish that a major complication of diabetes is kidney disease (diabetic nephropathy), and a critical factor in its progression is the inability to empty the bladder regularly, which can lead to urinary tract infections and further kidney damage. As a driver required to travel for hours within Metro Manila, it was reasonable to infer that Barrios had to postpone urination, thereby increasing the risk of aggravating his pre-existing diabetes into fatal renal complications. This created a work-connection sufficient under a liberal construction of the law. The Court held that where such a basis for inferring aggravation by working conditions exists, compensation must be granted. The GSIS was ordered to pay the corresponding death benefits.