G.R. No. L-46654 August 9, 1988
LUPO S. CARBAJAL, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM (Municipality of San Julian, Eastern Samar), and EMPLOYEES COMPENSATION COMMISSION, respondents.

FACTS

The petitioner, Lupo S. Carbajal, sought death benefits under Presidential Decree No. 626 (the Labor Code, as amended) following the demise of his spouse, Nenita P. Carbajal. Nenita was employed as a Campaign Clerk in the Municipal Treasurer’s Office of San Julian, Eastern Samar. On February 2, 1976, while performing her duties of typing tax declarations and making entries in books, she suffered from vaginal bleeding due to an incomplete abortion. She was hospitalized but died on March 8, 1976.
The Government Service Insurance System (GSIS) denied the claim, asserting the ailment was not occupational or causally related to her work. The Employees Compensation Commission (ECC) affirmed the denial, relying on its Medical Officer’s finding that there was no proof the sickness was compensable or that the risk of contracting it was increased by her working conditions.

ISSUE

The sole issue is whether the ailments (incomplete abortion leading to death) suffered by the deceased are compensable under P.D. No. 626.

RULING

The Supreme Court granted the petition, reversing the ECC decision. The legal logic centers on the interpretation of “compensable sickness” under the law, which includes any illness caused by employment, subject to proof that the risk of contracting it is increased by working conditions. The Court found the petitioner successfully provided substantial evidence establishing this increased risk.
The Court gave weight to the supporting documents, including reports from the Municipal Mayor and the Municipal Treasurer, and the Medical Certificate from the attending physicians. These indicated that the deceased’s work involved lifting heavy tax declaration books and travel, which caused two attacks of vaginal bleeding and hypogastric pain. This evidence aligned with established medical authorities cited by the Court, which state that heavy lifting, strain, or overmuscular exertion can cause spontaneous abortion in pregnant women, and that such activities are injurious and should be avoided.
The Court held that the contrary medical opinion of the ECC officer could not overcome this substantial evidence. It reiterated the doctrine that where there is a basis in the facts for inferring a work-connection, medical opinions to the contrary may be disregarded. Furthermore, the Court emphasized the liberal interpretation mandated by the Labor Code in favor of labor, aligning with the state policy to extend protection to employees. Consequently, the death was deemed compensable, and respondents were ordered to pay the full compensation benefits.