G.R. No. 58176 . March 23, 1984.
RUTH JIMENEZ, Petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, Respondents.

FACTS

The petitioner, Ruth Jimenez, is the widow of Sgt. Alfredo Jimenez of the Philippine Constabulary. He enlisted in 1969 after being found physically and mentally healthy. His duties involved field assignments, exposure to the elements, irregular hours, and providing security for a doctor, which required constant accompaniment. In April 1976, he suffered an accident when he fell from a bus due to a sudden stop. He was later diagnosed with a mass on his right forearm and, ultimately, bronchogenic carcinoma (lung cancer). He died from this ailment on May 12, 1980. The PC Regional Board found he “died in line of duty” and recommended payment of benefits to his heirs.
Petitioner received benefits under Republic Act No. 610 but filed an additional claim for death benefits under Presidential Decree No. 626, as amended. The GSIS denied the claim, stating the sickness was not work-connected. The Employees’ Compensation Commission affirmed, citing medical authorities that linked lung cancer primarily to cigarette smoking and certain industrial exposures, finding no causal link between the disease and his duties as a soldier.

ISSUE

Whether the death of Sgt. Alfredo Jimenez due to bronchogenic carcinoma is compensable under P.D. No. 626, as amended.

RULING

Yes, the death is compensable. The Supreme Court reversed the decision of the ECC. The legal logic centers on the application of the “reasonable work-connection” rule and a liberal interpretation of the compensation law in favor of labor.
The Court rejected the ECC’s rigid requirement for direct causation. It emphasized that in compensation cases, strict rules of evidence do not apply; only a reasonable work-connection or proof that the working conditions increased the risk of contracting the disease is required. The Court noted that when Jimenez entered service, he was healthy. His duties as a soldier, particularly field assignments involving exposure to dust, dirt, chemicals from ammunition, irregular hours, fatigue, and psychological stress, constituted hazardous conditions that could have influenced the development of his ailment.
The Court found the ECC’s reliance on statistics about smoking to be inconclusive and not a definitive refutation of a possible work connection. It cited the precedent in Dator v. ECC, where bronchogenic carcinoma was deemed compensable for a librarian exposed to dust from books. The Court reasoned that a soldier’s environment is inherently more hazardous. This aligns with the constitutional and statutory policy to give maximum aid and protection to labor. Therefore, a reasonable work-connection was established, warranting the award of death benefits, medical reimbursement, and burial expenses to the petitioner.