G.R. No. L-65216 December 1, 1987
Flerida Ovenson, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System, respondents.

FACTS

Serafin Ovenson, a senior trade analyst at the Central Bank, died at age 49 from adenocarcinoma of the rectum. His widow, Flerida Ovenson, filed a claim for death benefits under P.D. No. 626, as amended. The GSIS denied the claim, finding the ailment attributable to genetic influence and not causally related to his employment duties, which involved reviewing trade documents and preparing reports. The ECC affirmed the denial, citing medical authorities stating the disease’s etiology is unknown but commonly occurs in the 50-60 age decade, with no established link to his work conditions.
Petitioner appealed, arguing the ECC overlooked her husband’s employment conditions. She contended that during his early career as a laborer and janitor, he was exposed to chemicals, acids, disinfectants, and potential parasitic infestation. She further asserted that physical and mental stress from his employment could have weakened his immune system, contributing to cancer growth, citing contemporary scientific opinion on stress as a factor.

ISSUE

Whether the cancer of the rectum that caused Serafin Ovenson’s death is compensable as a sickness caused or aggravated by his employment.

RULING

Yes. The Supreme Court granted the petition, reversing the ECC decision. The legal logic proceeds from the framework of P.D. No. 626. While adenocarcinoma of the rectum is not a listed occupational disease, compensability may still be established under the second mode: any illness caused by employment, subject to proof that the risk of contracting it is increased by working conditions.
The Court applied the liberal interpretation principle consistent with the constitutional mandate of social justice. It cited its ruling in Mercado, Jr. v. ECC, which held that where the cause of an ailment is unknown or undetermined by medical science, the requirement of proving a causal link between the ailment and working conditions must be liberalized. It is grossly inequitable to impose an impossible burden of proof on a claimant, who is not conversant with medical intricacies and lacks resources to hire experts, especially after decades of contribution to the state insurance fund.
The Court found merit in petitioner’s allegations of exposure to chemical carcinogens and health hazards during the decedent’s early years of service, compounded by job-related stress. Given the unknown etiology of cancer, these working conditions provided a sufficient basis for inferring a work connection. The Court thus ordered the respondents to pay the full compensation benefits.