GR 44899; (April, 1981) (Digest)
G.R. No. L-44899 April 22, 1981
MARIA E. MANAHAN, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GSIS (LAS PIÑAS MUNICIPAL HIGH SCHOOL), respondents.
FACTS
Nazario Manahan, Jr., a classroom teacher at Las Piñas Municipal High School, died of “Enteric Fever” on May 8, 1975. His widow, Maria E. Manahan, filed a claim for death benefits under Presidential Decree No. 626. The Government Service Insurance System (GSIS) denied the claim, finding that typhoid fever (a related ailment) is not an occupational disease. The Employees’ Compensation Commission (ECC) affirmed the denial, ruling that the deceased’s enteric fever was not induced or aggravated by his teaching duties.
The petitioner argued that her husband was in perfect health upon entering service in 1969 but was treated for epigastric pain in December 1974. She cited medical authorities stating that enteric fever is caused by ingesting food or water contaminated with Salmonella organisms, often spread by human carriers or flies. As a teacher, the deceased regularly ate at the school canteen and used school facilities, which increased his risk of exposure to such contamination.
ISSUE
Whether the death of Nazario Manahan, Jr., due to enteric fever, is compensable under the applicable employees’ compensation law.
RULING
Yes, the death is compensable. The Supreme Court reversed the ECC decision. The legal logic proceeds from determining the applicable law. The medical evidence indicated the deceased’s illness (evidenced by epigastric pain in 1974) likely had its onset before December 10, 1974. Following the precedent in Corales vs. ECC, claims accruing prior to January 1, 1975, are governed by the Workmen’s Compensation Act. Under that Act, the presumption of compensability operates in favor of the claimant.
The Court applied this presumption, noting that the constitutional mandate of social justice and protection to labor requires a liberal construction of social legislation. Crucially, the ECC’s own findings established that the deceased, by eating at the school canteen and using school facilities, was exposed to the risk of ingesting contaminated food or water—the established mode of transmission for enteric fever. This working condition increased the risk of contracting the fatal disease. Therefore, the illness and resulting death are compensable. The GSIS was ordered to pay death benefits, attorney’s fees, and reimbursement for medical expenses.