GR 80157; (February, 1990) (Digest)
G.R. No. 80157 . February 06, 1990
AMALIA NARAZO, Petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION AND GOVERNMENT SERVICE INSURANCE SYSTEM (PROVINCIAL GOVERNOR’S OFFICE, NEGROS OCCIDENTAL), Respondents.
FACTS
Geronimo Narazo served as a Budget Examiner in the Office of the Governor, Negros Occidental, for thirty-eight years. His duties involved meticulous preparation of provincial budgets, financial reports, and review of municipal budgets, requiring prolonged sedentary work and intense concentration. On May 14, 1984, he died at age 57. Medical records indicated he suffered from urinary retention, abdominal pain, and anemia, with the final diagnosis being “Uremia” due to obstructive nephropathy from benign prostatic hypertrophy.
Petitioner Amalia Narazo, his widow, filed a claim for death benefits under PD 626, as amended. The GSIS denied the claim, ruling the cause of death was not a listed occupational disease and that his employment did not increase the risk of contracting it. The ECC affirmed, noting benign prostatic hypertrophy is common in men over fifty regardless of occupation, and uremia is a complication thereof. Petitioner contended the Commission failed to consider how his job—demanding long hours of sedentary work under pressure, often causing delayed urination—aggravated the risk of his fatal illness.
ISSUE
Whether the death of Geronimo Narazo is compensable under the Employees’ Compensation Law despite his ailment not being a listed occupational disease.
RULING
Yes. The petition is granted. Under PD 626, as amended, a compensable sickness includes any illness caused by employment if the claimant proves the risk of contracting it was increased by working conditions. While “Uremia” is not a listed occupational disease, compensability can be established under the increased risk theory, requiring only substantial evidence of reasonable work-connection, not direct causation.
The Court found the nature of the deceased’s work as a Budget Examiner, which necessitated prolonged sitting and intense concentration, often leading to delayed urination to maintain focus, created a predisposing factor for his urinary tract condition. This stagnation of urine encourages bacterial growth and infection, which can lead to complications like uremia. Citing Ceniza v. ECC, the Court recognized that such work habits, driven by job demands, aggravate the risk of contracting urinary-related illnesses. Therefore, petitioner successfully demonstrated that her husband’s working conditions increased the risk of his fatal ailment, making it work-connected. The ECC decision was reversed, and petitioner was awarded compensation benefits.