GR L 46894; (June, 1983) (Digest)
G.R. No. L-46894. June 24, 1983. TERESA M. ARMEÑA, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION AND GOVERNMENT SERVICE INSURANCE SYSTEM (Municipal Treasurer’s Office, Daraga, Albay), respondents.
FACTS
Patricio D. Armeña, husband of petitioner Teresa M. Armeña, was a government employee who served in various capacities, lastly as Municipal Treasurer of Daraga, Albay, from July 1, 1975, until his death on June 1, 1976. The certified cause of death was “acute monolytic leukemia.” Petitioner filed a claim for death benefits under the Employees’ Compensation Act (P.D. 626, as amended). The Government Service Insurance System (GSIS) denied the claim, finding no causal relation between the ailment and his duties as municipal treasurer, noting that acute monolytic leukemia is not a listed occupational disease.
Petitioner appealed to the Employees’ Compensation Commission (ECC), arguing that under the old Workmen’s Compensation Act ( Act No. 3428 ), an illness supervening during employment was presumed compensable, and this presumption should apply. The ECC affirmed the GSIS denial. It held that P.D. 626 expressly repealed the old law and its principle of presumptive compensability. For a non-listed disease like leukemia, the claimant must prove by substantial evidence that the risk of contracting the illness was increased by the working conditions. The ECC found no such proof in the record.
ISSUE
Whether the death of Patricio D. Armeña due to acute monolytic leukemia is compensable under P.D. 626, as amended.
RULING
No, the death is not compensable. The Supreme Court affirmed the ECC’s decision. The legal logic is anchored on the fundamental shift in the compensation regime under P.D. 626. The Court explicitly rejected the application of the doctrine of presumptive compensability from the repealed Workmen’s Compensation Act. Under the new law, for a non-occupational disease like leukemia, the claimant bears the burden of proving, by substantial evidence, that the illness was caused by employment and that the risk of contracting it was increased by the working conditions.
The Court examined the record and found no credible evidence establishing a causal link between the deceased’s work as a municipal treasurer and his fatal leukemia. Petitioner’s reliance on the case of Duran was misplaced, as the factual circumstances there—involving extreme physical exertion and exposure as a judge, and long-term administration of leukemogenic drugs—were not present here. The records showed the deceased’s hospitalizations began only in 1976, and there was no basis to conclude his illness accrued or was aggravated before January 1, 1975, which might have invoked a different consideration. Absent the required proof of work-connection, the claim must fail.