GR L 57416; (January, 1982) (Digest)
G.R. No. L-57416. January 30, 1982.
BAYANI DATOR, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.
FACTS
The petitioner, Bayani Dator, sought death benefits under Presidential Decree No. 626, as amended, following the demise of his spouse, Wenifreda Dator. The deceased served as a municipal librarian for the Municipality of Lopez, Quezon, from 1963 until her forced disability retirement on November 11, 1978, due to her illness. She underwent treatment at several hospitals and ultimately died on December 2, 1979, at the Philippine General Hospital. The cause of death was diagnosed as Bronchogenic Carcinoma with Pleural Effusion, a form of lung cancer.
The Government Service Insurance System (GSIS) denied the claim, a decision affirmed by the Employees’ Compensation Commission (ECC). The ECC ruled that bronchogenic carcinoma is not an occupational disease for a librarian, noting its statistical prevalence in males and its strong association with heavy cigarette smoking. The Commission found no conclusive evidence linking the disease to the decedent’s specific work environment, thereby requiring a direct causal connection between her employment and her illness for compensability.
ISSUE
Whether the death of Wenifreda Dator, caused by bronchogenic carcinoma, is compensable under the Employees’ Compensation Act (PD 626, as amended).
RULING
Yes. The Supreme Court reversed the decision of the Employees’ Compensation Commission and granted the claim for death benefits. The Court rejected the ECC’s stringent requirement for a direct and conclusive causal link between the employment and the illness. It emphasized that the exact etiology of cancer, including bronchogenic carcinoma, remains medically unknown. Following its precedent in Cristobal vs. Employees’ Compensation Commission, the Court held that what the law requires is not absolute medical certainty but substantial evidence of a reasonable work-connection.
The Court found such substantial evidence present. The deceased worked for approximately fifteen years in a library, consistently exposed to dusty books and potentially unsanitary conditions. These environmental factors are recognized as potential predisposing or risk-increasing elements for the development of cancer. The liberal and compassionate spirit of the labor laws, which mandates resolving all doubts in favor of the worker, supports this interpretation. Therefore, a reasonable work-connection was established, making the illness compensable. The GSIS was ordered to pay the petitioner death benefits, reimburse medical expenses, and provide funeral assistance.
