GR L 66174; (July, 1986) (Digest)
G.R. No. L-66174 July 22, 1986
ANGELES BRAVO, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.
FACTS
Evelio Bravo was employed at the Bureau of Coast and Geodetic Survey, rising to the position of litho-photo engraving supervisor. His duties involved supervising the formulation of light-sensitive lithographic chemicals, including various acids and reagents. In November 1979, he experienced symptoms leading to a diagnosis in April 1980 of adenocarcinoma of the sigmoid colon (Duke’s C) and chronic peri-appendicitis. After hospitalization and surgery, he retired on June 1, 1980, and subsequently filed a claim for disability benefits under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, finding the ailments non-occupational and not causally linked to his employment. Bravo died on August 20, 1981, and his widow, Angeles, pursued the appeal. The Employees’ Compensation Commission affirmed the denial, holding the ailments were too remote from his work conditions, as medical opinion associated colon cancer with specific pathological conditions like polyposis and inflammatory diseases, not chemical exposure.
ISSUE
Whether the cancer of the colon and peri-appendicitis that caused Evelio Bravo’s death are compensable under the Labor Code’s Employees’ Compensation Program.
RULING
The Supreme Court denied the petition and affirmed the decision of the Employees’ Compensation Commission. The legal logic centers on the applicable standard of proof under the Labor Code’s compensation scheme, which replaced the old Workmen’s Compensation Act. For a non-listed illness like cancer of the colon to be compensable, the claimant must prove by substantial evidence that the risk of contracting the disease was increased by the employee’s working conditions. The Court found that petitioner Angeles Bravo failed to meet this burden. While she alleged Bravo’s exposure to chemicals created a “probability” of work-connection, she presented no convincing medical or scientific proof to establish a causal link between the specific chemical exposures and the development of colon cancer. The Court noted medical authorities associated the disease with other recognized predisposing factors, not the cited chemicals.
The Court distinguished this case from prior rulings like Panotes v. ECC, where compensability was found for diseases of unknown origin, by emphasizing that in those cases, claimants presented concrete proofs of their working conditions. Here, mere enumeration of chemicals, without substantiating how they increased the risk of this specific cancer, was insufficient. The Court also held that ECC Resolutions Nos. 2610 and 2677, which provided guidelines for cancer cases, were prospective and, even if applied, required formal medical confirmations not submitted. While social legislation calls for liberal interpretation, the Court ruled it cannot engage in judicial legislation by awarding benefits without the requisite clear medical basis mandated by the present law. Thus, absent substantial proof of increased risk, the claim was not compensable.