G.R. No. 217866. June 20, 2022.
Social Security System, Petitioner, vs. Violeta A. Simacas, Respondent.

FACTS

Irnido L. Simacas worked as a Fabrication Helper from 1995 to 2010, assisting in cutting steel materials. Two years before retirement, he developed back pains and a persistent cough. After being cleared by a company clinic, his condition worsened, leading to his retirement. He was subsequently hospitalized and diagnosed with conditions including prostatic adenocarcinoma (prostate cancer). Irnido died in July 2010, with the death certificate stating the cause as cardiopulmonary arrest secondary to metastatic prostatic adenocarcinoma.
Violeta A. Simacas, Irnido’s widow, filed a claim for death benefits under Presidential Decree No. 626, as amended. The Social Security System (SSS) and the Employees’ Compensation Commission (ECC) denied the claim. They ruled that prostate cancer is a non-occupational disease and that Violeta failed to prove that Irnido’s working conditions increased the risk of contracting it. The Court of Appeals reversed this decision, applying a liberal interpretation of the law. It cited the case of GSIS v. Court of Appeals, noting the medical unknown etiology of prostate cancer made it impossible to present direct evidence of causation, and emphasized the social legislation purpose of the law.

ISSUE

The primary issue is whether Violeta A. Simacas is entitled to death benefits, specifically whether she presented substantial evidence to prove that the risk of contracting Irnido’s non-occupational disease (prostate cancer) was increased by his working conditions.

RULING

Yes, the Supreme Court denied the SSS’s petition and affirmed the Court of Appeals, granting death benefits to Violeta Simacas. The legal logic is anchored on the principle that for a non-occupational disease to be compensable, the claimant must prove by substantial evidence that the risk of contracting the illness was increased by the employee’s working conditions. It is not required to establish direct causation; a reasonable work connection suffices.
The Court found that substantial evidence supported a reasonable work connection. Irnido’s work as a Fabrication Helper for 15 years involved strenuous activities like lifting heavy steel in a cramped, poorly ventilated area. While the exact cause of prostate cancer is medically unknown, the Court, referencing contemporary epidemiological studies, acknowledged that certain occupational exposures, such as to heavy metals and fumes, are considered potential risk factors. The combination of Irnido’s long-term exposure to such an environment and the nature of his physically demanding tasks constituted substantial evidence that his working conditions aggravated the risk of developing his fatal illness. The ruling reinforces the liberal interpretation of P.D. No. 626 as social legislation, favoring the worker when a reasonable work connection is established, without requiring scientific certainty of direct causation.