G.R. No. L-48605 December 14, 1981
DOMNA N. VILLAVERT, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION & GOVERNMENT SERVICE INSURANCE SYSTEM (Philippine Constabulary), respondents.

FACTS

Petitioner Domna N. Villavert is the mother of Marcelino N. Villavert, who was employed as a Code Verifier in the Philippine Constabulary. Marcelino died on December 12, 1975, from acute hemorrhagic pancreatitis. His mother filed a claim for death benefits under P.D. No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, ruling that the ailment was not an occupational disease and that no causal link to his employment was established. The Employees’ Compensation Commission (ECC) affirmed this denial.
The records show that Marcelino’s duties extended beyond code verification to include computer operation and clerical typing. On December 11, 1975, he performed strenuous work and was required to render overtime late into the evening to prepare classified communications and payroll checks. He returned home fatigued, went to bed without eating, and was later found in acute distress. He was rushed to the hospital, where he was pronounced dead the following morning. Supporting certifications from his commanding officer and chief clerk detailed his excessive workload, exposure to temperature extremes, irregular meals due to work demands, and the lack of time for medical check-ups, all of which allegedly aggravated his condition.

ISSUE

Whether the death of Marcelino N. Villavert from acute hemorrhagic pancreatitis is compensable under the Employees’ Compensation Act.

RULING

Yes, the death is compensable. The Supreme Court reversed the ECC decision. The legal logic centers on the interpretation of the presumption of compensability and the principle of resolving doubts in favor of labor under the Labor Code. While acute hemorrhagic pancreatitis is not listed as an occupational disease, compensation is still warranted if the risk of contracting the disease is increased by the working conditions. The Court found that the strenuous overtime work, extreme fatigue, and irregular eating habits directly resulting from Marcelino’s urgent duties constituted working conditions that increased the risk of, or at least aggravated, his fatal ailment. The detailed certifications provided substantial evidence of this causal connection. The Court rejected the application of a rigid requirement for direct proof, emphasizing that the constitutional mandate for social justice and the labor-friendly intent of the law compel a liberal interpretation in favor of the employee’s heirs. Consequently, GSIS was ordered to pay the death benefits.