G.R. No. 193500. November 20, 2017
GOVERNMENT SERVICE INSURANCE SYSTEM, Petitioner, vs. SIMEON TAÑEDO, JR., Respondent.

FACTS

Respondent Simeon Tañedo, Jr., a records officer at the Bureau of Internal Revenue, filed a claim for disability benefits with the GSIS due to varicose veins in his legs. His duties involved encoding, printing, and delivering documents. The GSIS denied his claim, stating varicosities is not a listed occupational disease under Presidential Decree No. 626, as amended. The Employees’ Compensation Commission affirmed the denial, ruling Tañedo failed to prove that the risk of contracting his ailment was increased by his working conditions, noting medical science identifies familial tendency as the primary predisposing factor.
The Court of Appeals reversed the ECC decision and granted Tañedo’s claim. It reasoned that his job required prolonged standing and walking, which could aggravate varicose veins, and that the GSIS did not sufficiently rebut the presumption of compensability. The appellate court ordered the GSIS to pay compensation benefits. The GSIS filed this petition for review, arguing the Court of Appeals erred in finding the illness work-connected.

ISSUE

Whether Tañedo’s varicose veins are compensable under P.D. No. 626, as amended.

RULING

No. The Supreme Court granted the GSIS’s petition and reinstated the ECC decision denying the claim. Under the Amended Rules on Employees’ Compensation, for a non-listed sickness like varicose veins to be compensable, the employee must prove by substantial evidence that the risk of contracting the disease is increased by the working conditions. The legal logic requires a claimant to demonstrate a causal link between the illness and the employment, moving beyond mere possibility to establish that the working conditions significantly elevated the risk.
Here, Tañedo failed to present substantial evidence, such as medical opinion or scientific data, proving that his specific duties as a records officer—which included encoding, delivery, and filing—increased the risk of developing or aggravating varicose veins beyond the ordinary risks of daily life. The Court emphasized that while P.D. No. 626 is social legislation, it is not intended to cover all ailments; it requires proof of work-connection. The appellate court’s reliance on a general presumption was misplaced, as the law discarded the presumption of compensability. Without credible evidence showing his job conditions posed an elevated risk, the claim cannot be granted.