G.R. No. 58879 November 14, 1991
Expedita Librea, petitioner, vs. Employees Compensation Commission and Government Service Insurance System (Ministry of Education and Culture), respondents.

FACTS

Petitioner Expedita Librea, widow of public school teacher Eufronio Librea, filed a claim for death benefits under P.D. No. 626, as amended. Eufronio served for 32 years, eventually becoming a Division Physical Education Supervisor. In 1978, he experienced symptoms leading to a diagnosis of terminal cirrhosis of the liver, from which he died in July 1980. His attending physician certified the illness may have been directly caused by his duties.
Petitioner’s claim detailed that her husband’s work involved strenuous physical inspections of remote barrio schools, exposure to adverse weather, irregular meals, unhygienic eating habits, and hectic schedules for regional sports meets, which allegedly weakened his health. The GSIS denied the claim, finding no causal connection between cirrhosis and his work conditions. The Employees’ Compensation Commission affirmed the denial, stating that work stress and irregular meals are not medically accepted predisposing causes for liver cirrhosis.

ISSUE

Whether the death of Eufronio Librea due to cirrhosis of the liver is compensable under P.D. No. 626, as amended, specifically, whether his employment increased the risk of contracting the disease.

RULING

The Supreme Court DENIED the petition, affirming the decisions of the GSIS and ECC. The legal logic under the applicable law, P.D. No. 626, as amended, requires the claimant to prove that the illness was caused by the employment and that the risk of contracting the disease was increased by the working conditions. This represents a shift from the previous system of presumptions of compensability to a regime requiring positive proof of work-connection.
The Court found that the petitioner failed to meet this burden of proof. The medical etiology of cirrhosis of the liver, as presented, identifies malnutrition—specifically a diet deficient in protein and choline—and alcoholism as primary factors, not the stress, strain, or meal irregularity cited from the decedent’s work. The nature of his duties as a teacher and supervisor, while demanding, was not shown to have involved exposure to specific hazards known to cause liver cirrhosis. The disease is one to which the general population is exposed, irrespective of occupation. Therefore, absent substantial evidence that the employment increased the risk of contracting the ailment, the claim cannot be granted. The decision underscores the application of the social security principle under the new law, which does not allow compensation based merely on presumption or the manifestation of illness during employment.