GR 46545; (October, 1980) (Digest)
G.R. No. L-46545 October 30, 1980
SUSANA M. LEAL, petitioner, vs. EMPLOYEES COMPENSATION COMMISSION AND THE GOVERNMENT SERVICE INSURANCE SYSTEM (National Irrigation Administration), respondents.
FACTS
Petitioner Susana M. Leal filed a claim for death benefits under Presidential Decree No. 626, as amended, following the death of her husband, Anacleto A. Leal. Anacleto was employed as a ditchtender by the National Irrigation Administration in Urdaneta, Pangasinan. His duties involved cleaning canals, lateral gates, and conduits of deposits and debris, inspecting and repairing damaged canals, and preventing unauthorized water diversion. This work required him to be in the field extensively, both day and night. He died on April 15, 1976, and the cause of death was diagnosed as “severe anemia secondary to gastric malignancy.”
The Government Service Insurance System (GSIS) denied the claim, asserting that severe anemia secondary to gastric malignancy is not listed as an occupational disease. The Employees Compensation Commission (ECC) affirmed this denial upon appeal. The ECC’s Medical Division, however, noted in its findings that one of the predisposing factors for gastric malignancy could be environmental, such as rural residence.
ISSUE
Whether the death of Anacleto A. Leal, caused by severe anemia secondary to gastric malignancy, is compensable under the Employees’ Compensation Act despite not being a listed occupational disease.
RULING
Yes, the death is compensable. The Supreme Court reversed the decision of the Employees Compensation Commission. The legal logic hinges on the principle that compensability under PD 626 is not strictly limited to listed occupational diseases. An ailment not listed can still be compensable if there is a showing that the risk of contracting the disease was increased by the working conditions.
The Court found that the nature of Anacleto Leal’s duties as a ditchtender, which constantly exposed him to the elements—heat and other environmental factors—while working in rural fields, ultimately weakened his physical condition. This work-related exposure was a contributing factor that led to the development of his gastric malignancy, which in turn caused the severe anemia that resulted in his death. The Court gave weight to the ECC Medical Division’s own finding regarding environmental factors as a predisposition. Therefore, a causal link between his employment and his fatal illness was sufficiently established. The GSIS was ordered to pay death benefits, attorney’s fees, and funeral expenses to the petitioner.