GR 49280; (April, 1980) (Digest)
G.R. No. L-49280 April 30, 1980
LUZ G. CRISTOBAL, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (National Science Development Board), respondents.
FACTS
Fortunato S. Cristobal, a Supervising Information Officer II at the National Science Development Board (NSDB), was diagnosed with rectal malignancy in April 1976. Despite medical treatment, including surgery, he succumbed to the illness on May 27, 1977. His widow, Luz G. Cristobal, filed a claim for death benefits under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, stating that rectal cancer is not a listed occupational disease and that the claimant failed to prove a direct causal relationship between the employment and the ailment. The Employees’ Compensation Commission (ECC) affirmed the GSIS decision.
The petitioner presented evidence that the deceased was assigned to the NSDB’s Printing Department, where he was exposed to various chemicals, intense heat, and unhygienic conditions. An affidavit from a co-employee, Angel Peres, corroborated these working conditions and stated that the deceased’s illness became more painful during work. A medical certificate from Dr. Rufo A. Guzman also indicated that the illness may have been aggravated by the unhygienic conditions, handling of chemicals, and work pressure. It was undisputed that the deceased entered government service in good health and that the illness supervened during his employment.
ISSUE
Whether the petitioner is entitled to death benefits under P.D. No. 626 for her husband’s death from rectal malignancy, despite it not being a listed occupational disease.
RULING
Yes. The Supreme Court granted the petition and set aside the ECC decision. The legal logic centers on the application of the “increased risk” theory under the implementing rules of P.D. No. 626. For a non-listed disease like rectal cancer to be compensable, the claimant must show by substantial evidence that the risk of contracting the disease was increased by the employee’s working conditions.
The Court found that the ECC and GSIS failed to properly appreciate the evidence. The affidavit of the co-employee and the supporting medical certificate constituted substantial evidence that the deceased’s work environment—characterized by exposure to chemicals, heat, poor hygiene, and work pressure—increased the risk of contracting his fatal illness. The Court emphasized that where the precise cause of a disease like cancer remains unknown to science, it is unreasonable to require the claimant to prove direct causation with absolute certainty. The fact that the illness supervened during employment, coupled with the proven hazardous working conditions, satisfies the requirement of work-connection under the law. The respondent agencies were ordered to pay the corresponding death benefits, reimbursement for medical expenses, funeral benefits, and attorney’s fees.