G.R. No. L-56576, September 2, 1983
ZENAIDA SANTARIN, Petitioner, v. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (Commission on Audit), Respondents.

FACTS

Demetrio Santarin, employed as a helper-filer at the Commission on Audit for over thirteen years, died on November 13, 1975. The cause of death was diagnosed as cor pulmonale due to chronic obstructive lung disease, probably status asthmaticus, with pneumonitis. The medical history indicated he had been suffering from asthma for approximately twenty years prior to his death. His duties involved bundling publications, carrying files and vouchers, and assisting with office machines. On November 10, 1975, he developed acute respiratory distress with chest pains while at work and was subsequently hospitalized.
Petitioner Zenaida Santarin, his widow, filed a claim for death benefits under the Employees’ Compensation Program. The Government Service Insurance System (GSIS) denied the claim, reasoning that the ailments were not occupational diseases and that his employment conditions could not have directly caused, but at most only aggravated, his pre-existing condition—a factor no longer compensable under the new Labor Code provisions. The Employees’ Compensation Commission (ECC) affirmed this dismissal, emphasizing the deceased had asthma long before his government service and his physician certified the illness was not directly caused by his duties.

ISSUE

Whether the claim for death benefits is governed by the provisions of the former Workmen’s Compensation Act or by the new Employees’ Compensation Program under the Labor Code, and consequently, whether the death is compensable.

RULING

The Supreme Court reversed the ECC decision and granted the claim. The legal logic hinges on the applicable law based on the accrual date of the cause of action. The Court, citing Corales v. Employees Compensation Commission and Javier v. Employees Compensation Commission, held that the Employees’ Compensation Program under Title II, Book IV of the Labor Code applies only to injury, sickness, disability, or death accruing on or after January 1, 1975. Since Demetrio Santarin’s illness and death originated from a condition that existed long before this date, his claim is governed by the former Workmen’s Compensation Act.
Under the Workmen’s Compensation Act, the principle of aggravation applies. The law presumes compensability if the illness supervened during employment, and the employer bears the burden to disprove either the occurrence of illness or its aggravation by work. Here, the fatal acute episode occurred while Santarin was at work. The Court found that the demands of his employment, which included physical exertion and exposure to dust from papers and machines, could have aggravated his pre-existing chronic asthmatic condition, leading to his death. Therefore, the death is compensable. The GSIS was ordered to pay death compensation, burial expenses, and attorney’s fees.