G.R. No. L-50954 February 8, 1989
EDUARDO SIERRA, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM, EMPLOYEES’ COMPENSATION COMMISSION, PHILIPPINE COAST GUARD, respondents.

FACTS

Petitioner Eduardo P. Sierra was employed by the Philippine Coast Guard for approximately 25 years, holding various positions including boatman, laborer, and driver. He retired on May 1, 1976, due to amoebic colitis, adenocarcinoma rectum, and anemia. On September 30, 1976, he filed a claim for income benefits under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied his claim, ruling that his ailments were not occupational diseases listed for his employment and that he failed to prove they resulted directly from his work. The GSIS explained that amoebic colitis is an infectious disease typically acquired from contaminated food or water, adenocarcinoma rectum has genetic predispositions, and anemia in his case was likely secondary to blood loss from his other conditions.
Sierra sought reconsideration, but the GSIS denied it. He then appealed to the Employees’ Compensation Commission (ECC), which sustained the denial. The ECC, applying the “increased risk” theory, found no compelling evidence that the risk of contracting these ailments was increased by his working conditions as a driver. Sierra subsequently elevated the case to the Supreme Court via a petition for review on certiorari.

ISSUE

The primary issue is whether Sierra’s ailments—amoebic colitis, adenocarcinoma rectum, and anemia—are compensable under P.D. No. 626, as amended.

RULING

The Supreme Court did not reach a substantive ruling on the compensability of the ailments. Instead, it resolved the case based on a subsequent development. The records revealed that on January 14, 1987, the ECC, through Resolution No. 2880, requested the Office of the Solicitor General to withdraw this case and similar cases from the Supreme Court to facilitate the payment of compensation benefits. This resolution specifically included Sierra’s claim. The ECC’s action was in line with its declared policy of adopting a liberal and compassionate interpretation of P.D. No. 626.
The Office of the Solicitor General, representing the public respondents, filed a Manifestation with the Court stating it had no objection to the ECC’s request for withdrawal to allow payment to Sierra. Consequently, the Supreme Court, noting the ECC’s resolution and the Solicitor General’s non-opposition, considered the case WITHDRAWN. The Court’s resolution effectively terminated the proceedings, enabling the processing and payment of Sierra’s compensation benefits without adjudicating the legal merits of his claim under the strict provisions of the law.