G.R. No. L-47414 December 11, 1987
ELIODORO T. ISCALA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Dept. of Education & Culture, Bureau of Public Schools), GOVERNMENT SERVICE INSURANCE SYSTEM, ET AL., respondents.

FACTS

Nena S. Iscala, an elementary school teacher for fifteen years, first underwent medical treatment for a peptic ulcer in September 1969. She received subsequent treatments for the same ailment on multiple occasions from 1970 to 1974. On February 25, 1975, she was hospitalized for Amoebic Abscess and died on March 1, 1975, from Acute Pancreatitis and Recurrent Duodenal Ulcer. Her surviving spouse, Eliodoro Iscala, filed a claim for death benefits under the new Employees’ Compensation Act (Presidential Decree No. 626).
The Government Service Insurance System (GSIS) denied the claim, a decision affirmed by the Employees’ Compensation Commission (ECC). The ECC applied P.D. 626, which took effect on January 1, 1975, and held the cause of death was not a listed occupational disease. It further ruled that the petitioner failed to prove that the risk of contracting the ailment was increased by the deceased’s working conditions, as required under the new law.

ISSUE

Whether the claim for death benefits should be governed by the old Workmen’s Compensation Act or the new Employees’ Compensation Act (P.D. 626), and consequently, whether the claim is compensable.

RULING

The Supreme Court granted the petition, ruling that the old Workmen’s Compensation Act applies. Although Nena Iscala died on March 1, 1975, after P.D. 626’s effectivity, the cause of action accrued in 1969 when her illness first manifested. Following the principle that rights accrued under a prior statute survive its repeal, the Court applied the old law.
Under the Workmen’s Compensation Act, when an illness supervenes in the course of employment, there exists a legal presumption that the sickness arose out of or was aggravated by said employment. The burden to rebut this presumption lies with the employer. The Court found that the employer failed to present convincing proof to overthrow this presumption. The attending physician’s opinion that the duties did not directly cause the ailment was insufficient. The law only requires that the employment contributed, even in a small degree, to the development of the disease, and the claimant need only show probability, not absolute certainty. As social legislation, its provisions must be liberally construed in favor of labor. Consequently, the ECC decision was set aside, and the GSIS was ordered to award the appropriate compensation under the Workmen’s Compensation Act.