GR L 68648; (September, 1986) (Digest)
G.R. No. L-68648 September 24, 1986
MARTINIANO SARMIENTO, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents.
FACTS
Martiniano Sarmiento, a casual laborer for the Bureau of Agricultural Extension, was required to handle plants sprayed with insecticides and pesticides. In February 1983, he manifested symptoms including fever, chest pain, cough, and nasal discharge. He was later diagnosed with acute follicular pharyngitis with hypertrophic rhinitis. He filed a claim for disability compensation under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied his claim, finding no occupational connection between his ailments and his work. The Employees’ Compensation Commission (ECC) affirmed this denial, stating there was no proof that the risk of contracting these diseases was increased by his working conditions.
ISSUE
The sole issue is whether Sarmiento’s ailments are compensable under P.D. No. 626, as amended.
RULING
The Supreme Court granted the petition and awarded compensation benefits. The legal logic centered on the application of the “increased risk” theory under the labor law’s compassionate spirit. For a non-listed illness to be compensable, an employee must show, by substantial evidence, that the risk of contracting the disease was increased by the working conditions. The Court clarified that this requires only a reasonable work-connection, not direct causal relation, and probability, not certainty, is the standard.
The Court found this standard met. Medical authorities established that chronic hypertrophic rhinitis is a reaction to long-term exposure to irritants like insect sprays, dusts, and fumes—conditions inherent to Sarmiento’s job involving pesticides. The “chronic” nature of his rhinitis indicated a gradual development linked to prolonged workplace exposure. This condition weakened his constitution, increasing his susceptibility to infections like follicular pharyngitis. Thus, a logical and close link between his employment and his ailments was established. The Court emphasized that all doubts in implementing labor legislation must be resolved in favor of the worker, and the ECC’s reliance on medical opinions dismissing work-connection was erroneous given the factual basis for inferring a probable connection. The decision of the ECC was set aside, and the GSIS was ordered to pay the corresponding disability benefits.