G.R. No. 95595 ; July 8, 1991
JOSE DE GUIA, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION AND GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.

FACTS

Petitioner Jose De Guia, a long-time employee of the Bureau of Internal Revenue who retired as a Supervising Revenue Enforcement Officer, filed a claim for compensation benefits under P.D. No. 626. He claimed that his ailment, “Proliferative Diabetic Retinopathy with Vitreous Hemorrhage,” which caused visual impairment, was work-connected. He argued that his duties as a Revenue Examiner, involving endless hours examining voluminous tax returns, subjected him to constant physical and mental stress, which he alleged were medically recognized predisposing factors for diabetes, the underlying condition of his eye ailment.
The Government Service Insurance System (GSIS) denied his claim, a decision affirmed by the Employees’ Compensation Commission (ECC). The ECC ruled that diabetes mellitus is not listed as an occupational disease and that the records were bereft of evidence showing a causal relation between his ailment and his employment or working conditions. The ECC noted diabetes is a disorder of carbohydrate metabolism where genetic susceptibility plays a key role.

ISSUE

Whether petitioner’s ailment, “Proliferative Diabetic Retinopathy with Vitreous Hemorrhage,” is compensable under the Employees’ Compensation Law.

RULING

The Supreme Court denied the petition and affirmed the ECC’s decision. The legal logic is anchored on the burden of proof under P.D. No. 626. For a non-listed illness like diabetes mellitus to be compensable, the claimant must prove that the risk of contracting the disease was increased by the working conditions. The Court found that petitioner failed to discharge this burden.
The Court clarified that “diabetic retinopathy” is a complication of the underlying disease, diabetes mellitus, from which petitioner had suffered for about twenty-five years. The ailment was not contracted by reason of his employment but arose as a complication of a pre-existing metabolic and familial disease. The Court noted that diabetes mellitus is predisposed by factors like heredity, obesity, or old age. While petitioner cited Millora v. ECC, which recognized stress as a potential predisposing factor, that case required a showing that the claimant was not predisposed by heredity, obesity, or old age. Here, no such proof was presented. The mere allegation of work stress, without evidence negating other predisposing factors or proving increased risk, is insufficient to establish compensability. Thus, no causal relation between his employment and his ailment was proven.