G.R. No. 58879 March 6, 1992
Expedita Librea, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Ministry of Education and Culture), respondents.

FACTS

The petitioner, Expedita Librea, is the widow of Eufronio Librea, a public school teacher who rose to Division Physical Education Supervisor and died on July 28, 1980. In 1978, he complained of loss of appetite, abdominal enlargement, and severe anemia. He was confined on July 2, 1980, diagnosed with terminal cirrhosis of the liver, and died from it on July 28, 1980. His attending physician certified the illness may have been caused by the nature of his duties. The widow filed a claim for death benefits with the GSIS, which was disapproved as not work-connected. Her motion for reconsideration argued his work was physically and mentally strenuous, involving regular inspections across districts, exposure to adverse weather, extraordinary fatigue, irregular meals, and unhygienic eating habits, which weakened his health. The GSIS denied the motion, and the ECC affirmed the denial. The petitioner brought the case to the Supreme Court. In a decision dated November 14, 1991, the Court initially set aside the ECC decision and ordered GSIS to pay death benefits, funeral expenses, and attorney’s fees. Both parties filed motions for reconsideration: the petitioner questioned the amount of the award, citing PD 1368 for lifetime monthly income benefits, while the GSIS argued the ailment was not work-connected under the Labor Code’s amended rules.

ISSUE

Whether the death of Eufronio Librea due to cirrhosis of the liver is compensable under the Employees’ Compensation Act.

RULING

The Supreme Court granted the respondent GSIS’s motion for reconsideration, denied the petitioner’s motion, set aside its November 14, 1991 decision, and denied the petition for certiorari for lack of merit. The Court held that under the present Labor Code scheme, the presumption of compensability no longer applies. For an illness not listed as compensable, the claimant must prove that the risk of contracting the disease was increased by the working conditions. The petitioner failed to show how the work of a public school teacher specifically increased the risk of contracting cirrhosis of the liver. The disease is one to which the general public is exposed, regardless of occupation, and is not proven to be caused by hard work, irregular meals, or unhygienic eating habits in this context. The Court emphasized that the amended rules are statutory and require proof of a causal connection, which was not substantiated.