G.R. No. L-47521; July 31, 1987
CAROLINA CLEMENTE, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM, Department of Health (Dagupan City) and EMPLOYEES’ COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Carolina Clemente sought death benefits under the Labor Code following the demise of her husband, Pedro Clemente, a janitor at the Ilocos Norte Skin Clinic for ten years. He died from uremia due to nephritis, also having been diagnosed with portal cirrhosis and Hansen’s disease (leprosy). The GSIS denied her claim, reasoning that these ailments were not occupational diseases listed under the rules and were not causally related to his duties. The Employees’ Compensation Commission affirmed, finding no substantial proof that his employment caused the illnesses and noting evidence suggesting he had Hansen’s disease prior to employment, making any aggravation non-compensable under the new law.
Petitioner appealed, arguing her husband’s work involved direct contact with skin disease patients and exposure to obnoxious dust, which increased the risk of contracting his ailments. She emphasized the liberal interpretation mandated for compensation claims. The respondents maintained that she failed to prove causation by substantial evidence and that aggravation of a pre-existing condition is no longer a compensable ground.

ISSUE

Whether the death of Pedro Clemente is compensable under the Employees’ Compensation Act.

RULING

Yes, the death is compensable. The Supreme Court reversed the ECC decision. Since the ailments were not listed as occupational diseases, compensability depended on proof that the risk of contracting them was increased by the working conditions. The Court applied the principle of liberal construction in favor of labor, noting that strict rules of evidence do not govern compensation claims.
The Court found it reasonable to conclude that Clemente’s decade-long work as a janitor in a skin clinic, with direct exposure to patients suffering from various skin diseases including leprosy and to unsanitary conditions, increased the risk of contracting his illnesses. The respondents’ conservative posture conflicted with the constitutional mandate of social justice. The Court rejected the theory of mere aggravation of a pre-existing disease, as there was no evidence he was hired with a known existing illness; the more plausible explanation was a recurrence or new contraction due to increased occupational risks. When multiple inferences are possible, the one favoring the claimant must be adopted.
The Court also upheld the GSIS as a proper party, being the implementing agency for compensation benefits. The GSIS was ordered to pay petitioner P12,000 as death benefits and P1,200 as attorney’s fees.