GR 176832; (May, 2009) (Digest)
G.R. No. 176832 ; May 21, 2009
Government Service Insurance System, Petitioner, vs. Marian T. Vicencio, Respondent.
FACTS
Judge Honorato S. Vicencio served in government from 1964 until his death in 2001, culminating in his role as a Regional Trial Court Judge in Manila. In November 2000, he was diagnosed with Adenocarcinoma of the Left Lung with Metastases and underwent chemotherapy. He died on May 31, 2001. His Death Certificate listed the immediate cause as “Cardiopulmonary Arrest” and the antecedent cause as “T/C Fatal Arrythmia,” with the space for the underlying cause left blank.
Respondent Marian T. Vicencio, the judge’s widow, filed a claim for death benefits under Presidential Decree No. 626, as amended. The GSIS denied the claim, arguing the fatal illness—presumed to be lung cancer—was not a listed occupational disease and that the claimant failed to prove his work increased the risk of contracting it. The Employees’ Compensation Commission (ECC) upheld the denial. The Court of Appeals reversed the ECC, ordering GSIS to grant the claim, prompting GSIS to elevate the case to the Supreme Court.
ISSUE
Whether respondent’s claim for death benefits under P.D. No. 626, as amended, is compensable.
RULING
The Supreme Court denied the petition and affirmed the CA decision, holding the claim compensable. The legal framework under P.D. No. 626 requires the claimant to prove either that the sickness is a listed occupational disease with satisfied conditions, or that the risk of contracting the disease was increased by the working conditions. The Court resolved the ambiguity in the cause of death in favor of compensability, guided by the law’s nature as social legislation.
First, the Death Certificate’s listed cause, Cardiopulmonary Arrest T/C Fatal Arrythmia, qualifies as a cardiovascular disease, which is a listed occupational disease under the rules. While GSIS contended this was merely a complication of lung cancer, the records did not conclusively establish lung cancer as the underlying cause, as the Death Certificate left that portion blank. This uncertainty must be interpreted liberally in favor of the employee. Second, even assuming lung cancer was the cause, the Court agreed with the CA that the strenuous nature of Judge Vicencio’s judicial duties, involving immense mental and emotional strain, contributed to the development of his illness, thereby increasing the risk. The primordial purpose of the law is to provide meaningful protection to workers, and the constitutional guarantee of social justice demands a liberal attitude in favor of the employee in compensation claims.