G.R. No. 158268 ; April 12, 2006
Rhoda Castor-Garupa, represented by attorney-in-fact, Ms. Imelda C. Electona, Petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Bayawan District Hospital), Respondents.

FACTS

Petitioner Rhoda Castor-Garupa served as a Resident Physician and later as Medical Officer III at Bayawan District Hospital. In 1994, she began experiencing hypertension. By December 1998, she suffered extreme fatigue and weight loss, leading to hospitalization in February 1999. She was diagnosed with Chronic Renal Failure secondary to Intrinsic Renal Disease and underwent hemodialysis. A subsequent confinement at the National Kidney and Transplant Institute confirmed End Stage Renal Disease secondary to Chronic Glomerulonephritis, necessitating a kidney transplant.
She filed a claim for compensation benefits under Presidential Decree No. 626, as amended (the Employees’ Compensation Act). The GSIS denied her claim, stating that her diseases were not listed occupational illnesses under the law and that she failed to prove her work increased the risk of contracting them. The ECC affirmed the denial, emphasizing that the law requires the claimant to positively prove that the illness was caused by employment or that the working conditions increased the risk of contraction.

ISSUE

Whether petitioner’s Chronic Glomerulonephritis, which led to End Stage Renal Disease, is compensable under P.D. No. 626, as amended.

RULING

Yes. The Supreme Court granted the petition and reversed the Court of Appeals. The legal logic centers on the application of the increased-risk theory under the law. For a non-listed disease like Chronic Glomerulonephritis to be compensable, the claimant must show that the risk of contracting it was increased by the working conditions. The Court found this requirement satisfied.
The Court examined medical literature indicating that a common form of Glomerulonephritis occurs after a streptococcal infection of the throat or skin. As a resident physician in a 50-bed hospital, petitioner’s duties exposed her to various pathogens, including streptococcus, from attending to numerous patients. Her work involved extended hours in a high-risk environment, substantiating that the likelihood of infection was increased by her working conditions. While P.D. No. 626 abandoned the presumption of compensability, it remains a social legislation. The Court reiterated that a liberal interpretation in favor of the worker is mandated, aligning with the constitutional policy of social justice and compassion for employees whose health is compromised by service. Thus, her ailment was deemed work-connected and compensable.