GR L 56909; (November, 1982) (Digest)
G.R. No. L-56909 November 2, 1982
FLORENCIA B. SAN VALENTIN, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.
FACTS
The late Delfin San Valentin, husband of petitioner, worked for the Bureau of Plant Industry from 1951, eventually as a nursery farm aide tasked with plant cultivation and propagation. In 1979, he exhibited symptoms including jaundice and abdominal enlargement. He was confined at the Philippine General Hospital and diagnosed with hepatic encephalopathy, obstruction jaundice, and hepatoma, conditions leading to his death on July 28, 1979. Petitioner filed a claim for death benefits under PD No. 626, as amended. The GSIS denied the claim, asserting the ailments were not occupational diseases, a decision affirmed by the Employees’ Compensation Commission. The Commission cited medical authority stating cirrhosis causes are often unknown, with only a small percentage linked to industrial chemical intoxications, and found no proof of a causal relationship between the disease and the deceased’s employment conditions.
ISSUE
Whether the deceased’s fatal liver disease is compensable under the Employees’ Compensation Act.
RULING
Yes. The Supreme Court reversed the Commission’s decision. The legal logic centers on the application of the “increased risk” theory and the liberal construction mandated in compensation cases. Strict rules of evidence do not apply; only a reasonable work-connection is required. The Court found petitioner presented convincing proof that the deceased’s frequent exposure to plant chemicals and insecticides as a nursery farm aide increased his risk of contracting the disease, substantially complying with the required degree of proof. It emphasized that the test is probability, not certainty. Citing its policy in Sepulveda v. ECC for a compassionate interpretation of PD 626, especially for borderline cases like cirrhosis, the Court concluded the ailment was compensable by the nature of his work. Requiring proof of actual causation would contravene the constitutional policy of affording maximum protection to labor. The GSIS was ordered to pay death benefits, reimburse medical expenses, and pay attorney’s fees.