GR L 55645; (November, 1982) (Digest)
G.R. No. L-55645 November 2, 1982
RICARDO CENIZA, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and the GOVERNMENT SERVICE INSURANCE SYSTEM (Ministry of Education & Culture), respondents.
FACTS
Perpetua Ceniza, a public school teacher for over thirty years, died at age 49 from chronic pyelonephritis and uremia. Her husband, Ricardo Ceniza, filed a claim for death benefits under P.D. No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, finding the ailments not work-connected, as uremia was traceable to factors like infection, obstruction, or other diseases unrelated to teaching. The Employees’ Compensation Commission (ECC) affirmed the denial, noting the illnesses were not listed as occupational diseases for teachers and the attending physicians did not attribute them to her employment duties.
Petitioner argued that his wife entered government service in good health at age 17 and her thirty years of devoted service, under conditions of meager salary and likely inadequate school facilities, contributed to her physical deterioration. The respondent Commission maintained that the claimant failed to prove the required work-connection, as the ailments resulted from bacterial infection and renal failure not peculiar to the teaching profession.
ISSUE
Whether the death of Perpetua Ceniza from chronic pyelonephritis and uremia is compensable under the Employees’ Compensation Act.
RULING
Yes, the death is compensable. The Supreme Court reversed the ECC decision. While the illnesses are not listed as occupational diseases, compensability can be established if the risk of contraction was increased by the working conditions. The Court applied the legal principle that when an employee has served for a considerable period, like thirty years here, and contracts a disease leading to death, a rebuttable presumption arises that the illness is work-connected.
The Court reasoned that the demanding nature of teaching, with its inherent physical and nervous strain, coupled with low socioeconomic status and inadequate working facilities, could have aggravated the risk of developing her fatal renal conditions. Medical authorities cited indicate that urinary infections are influenced by socioeconomic status. Furthermore, Republic Act No. 4670 , the Magna Carta for Public School Teachers, mandates recognition of the effects of physical and nervous strain on health as compensable. The GSIS failed to present substantial evidence to overcome the presumption of compensability. Thus, the claim was granted, awarding death benefits, reimbursement for medical expenses, burial expenses, and attorney’s fees.