GR L 47460; (November, 1982) (Digest)
G.R. No. L-47460 November 2, 1982
AMELIA DELEGENTE, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (Bureau of Posts), respondents.
FACTS
The late Baltazar Delegente served as a letter-carrier and mail messenger for the Bureau of Posts for over thirty-four years until his death on May 28, 1976. He underwent surgery in October 1975, with a biopsy revealing metastatic well-differentiated epidermoid carcinoma of the thyroid gland. He filed a claim for compensation benefits under Presidential Decree No. 626, as amended. The GSIS denied the claim on March 25, 1976, stating his ailment was not an occupational disease and did not arise from his employment. The deceased, and later his widow Amelia, argued that his duties involved frequent contact with sources of tuberculosis infection and exposure to the elements, which may have caused his disease. The ECC affirmed the GSIS denial, finding the records devoid of proof connecting the ailment to his working conditions and noting the attending physician answered “No” when asked if the illness was directly caused by the employee’s duties.
ISSUE
Whether the death of Baltazar Delegente due to epidermoid carcinoma is compensable under the Employees’ Compensation Act (P.D. No. 626, as amended).
RULING
Yes. The Supreme Court set aside the decision of the ECC and granted the claim. The legal logic centers on the interpretation of the presumption of compensability and the principle of aggravation under the applicable law. While P.D. No. 626 had removed the statutory presumption of compensability for non-listed ailments, the Court emphasized that the claimant is not required to provide direct, positive, or absolute proof of a causal link. It is sufficient to show that the risk of contracting the disease was increased by the working conditions. The Court found that the deceased’s long years of strenuous duty as a letter-carrier, involving constant travel and exposure to all types of weather, dust, and dirt, undoubtedly weakened his physical condition. This weakened resistance constituted adequate proof that the risk of contracting his fatal ailment was increased by his employment. The Court held that where an illness supervenes during employment, it is presumed to be work-related, and the burden to disprove this shifts to the employer. The ECC and GSIS failed to present substantial evidence to overcome this presumption. Consequently, the claim is compensable.