GR 154386; (August, 2006) (Digest)
G.R. No. 154386 August 22, 2006
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), Petitioner, vs. ERNESTO A. VILLAMAYOR, Respondent.
FACTS
The late Dionisia Villamayor, a public school teacher who rose to District Supervisor, retired in June 1998. She had been diagnosed with breast cancer two years prior and succumbed to the illness in July 1998, with the death certificate listing respiratory arrest, pneumonia, and breast carcinoma as causes. Her husband, respondent Ernesto Villamayor, filed a claim for death benefits under P.D. No. 626 (Employees’ Compensation Law). The GSIS and the Employees’ Compensation Commission (ECC) denied the claim, ruling that breast cancer is not a listed occupational disease and that the claimant failed to prove it was work-related.
Respondent appealed to the Court of Appeals, which reversed the ECC and granted the claim. The CA reasoned that Villamayor’s demanding work, including an alleged 1989 incident where a ball hit her chest during a school inspection, contributed to her illness. The GSIS filed this petition, arguing the CA erred as there was no proof that the risk of contracting breast cancer was increased by the deceased’s working conditions.
ISSUE
Whether the respondent is entitled to death benefits under P.D. No. 626 for the death of his wife due to breast cancer.
RULING
No. The Supreme Court granted the GSIS petition and reinstated the ECC decision denying the claim. Under the law, for a non-listed illness like breast cancer to be compensable, the claimant must prove by substantial evidence that the risk of contracting the disease was increased by the employee’s working conditions. The Court found that respondent failed to meet this burden.
The medical records only established the fact of illness and death, not any causal link to her employment. The certifications regarding the chest injury were insufficient, as the issuers were not oncologists qualified to opine on the etiology of breast cancer. The Court cited medical authorities stating that the exact causes of breast cancer are unknown, with risk factors primarily relating to gender, age, genetics, and lifestyle—not occupational hazards of teaching. The antecedent cause of pneumonia was also not compensable, as it was a complication of the terminal cancer, not an independent, work-related illness. The claim, therefore, lacked the requisite medical or scientific basis to establish work-connection. While the law extends sympathy to beneficiaries, it must also protect the compensation fund from undeserving claims.