GR 89222; (April, 1993) (Digest)
G.R. No. 89222 . April 7, 1993.
Carmen Santos, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Philippine Navy), respondents.
FACTS
Francisco Santos was employed as a welder at the Philippine Navy and its Naval Shipyard from March 22, 1955, spending 32 years in government service. On December 29, 1986, he was hospitalized for epigastric pain and vomiting blood, diagnosed with bleeding Peptic Ulcer Disease, cholelithiasis, and diabetes mellitus. He died on January 11, 1987, with the cause of death indicated as liver cirrhosis. His widow, Carmen Santos, filed a claim for death benefits under P.D. No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, stating the ailment was not an occupational disease. This denial was affirmed by the Employees’ Compensation Commission (ECC), which noted the diagnosis did not specify the type of cirrhosis and that the deceased had no history of alcoholism, hepatitis, or biliary conditions. The petitioner substantiated that her husband’s duties as a Senior Welder required him to perform delicate welding jobs inside enclosed compartments of naval vessels, exposing him to heat and inhalation of burning chemical substances and gas fumes from welding electrodes.
ISSUE
Whether liver cirrhosis, an illness not listed as an occupational disease, is compensable under the Employees’ Compensation Act.
RULING
Yes. The petition is granted. The decision of the Employees’ Compensation Commission is reversed. While cirrhosis of the liver is not listed as an occupational disease, the claimant can still prove compensability by showing the risk of contracting the disease was increased by the working conditions. The Court, applying a liberal interpretation in favor of labor as mandated by the Labor Code, found that the nature of Francisco Santos’s work as a welder for 32 years, which involved exposure to heat, gas fumes, and chemical substances (such as carbon monoxide, carbon dioxide, sulfur, and phosphorus) from burning electrodes within enclosed compartments, likely caused poisoning and liver malfunction over time. This exposure increased the risk of contracting liver cirrhosis. The Court cited the precedent in Librea v. Employees’ Compensation Commission and emphasized that the Employees’ Compensation Act is social legislation designed to afford relief, and all doubts in its interpretation shall be resolved in favor of labor.