GR L 57889; (October, 1987) (Digest)
G.R. No. L-57889 October 28, 1987
FLAVIANO NEMARIA, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM (Ministry of Education and Culture), respondents.
FACTS
Petitioner Flaviano Nemaria sought death benefits under Presidential Decree No. 626 after his wife, Rosario Nemaria, a public school teacher for nearly thirty years, died from cancer of the liver, duodenal ulcer, and cancer of the breast. The respondent Government Service Insurance System (GSIS) denied the claim, a decision affirmed by the Employees’ Compensation Commission (ECC). The ECC ruled that these ailments were not listed as occupational diseases for teachers and that the petitioner failed to prove the illnesses were caused by or the risk of contracting them was increased by her employment conditions. The petitioner, pleading poverty, appealed to the Supreme Court.
ISSUE
Whether the death of Rosario Nemaria is compensable under P.D. No. 626.
RULING
Yes, the death is compensable. The Court granted the petition, reversing the ECC decision. The legal logic centers on the application of the “increased risk” theory under the employees’ compensation law. While the ailments were not listed occupational diseases, compensability can be established by showing that the risk of contracting the disease was increased by the working conditions. The degree of proof required is merely substantial evidence, not strict or stringent criteria.
The Court emphasized the liberal character of the compensation scheme aimed at social justice. Where the precise causes of a disease like cancer are unknown even to medical science, it is inequitable and impossible to demand absolute proof of a causal link to employment. The deceased teacher’s long service in remote municipalities, coupled with the inherent difficulties and stresses of the teaching profession, provided a reasonable basis to infer a work-connection. The law cannot demand an impossible condition from a claimant, especially one lacking medical expertise. Consequently, the claim was deemed compensable, and respondents were ordered to pay the full death benefits.