La O v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: This case concerns a claim for death benefits filed by Milagros B. La O, the widow of Perfecto V. La O, who died on February 7, 1977, after over 28 years of government service. Perfecto V. La O, who began his service in 1948, eventually became the chief of the cash division in the provincial treasurer's office. He experienced abdominal pains starting August 9, 1976, and continued working until October 1976, when his condition worsened, leading to a diagnosis of hepatoma (liver cancer). He was admitted to Quezon Memorial Hospital and died six days later from hypovolemic shock due to bleeding esophageal varices, a complication of his liver ailment. Procedural History: Milagros B. La O filed a claim for death benefits under P.D. 626, as amended, with the Government Service Insurance System (GSIS) on May 13, 1977. The GSIS denied the claim on the same date, stating that while hepatoma is listed as an occupational disease, the conditions for compensability were not met, and there was no substantial evidence that the ailment was largely brought about by his working conditions. After the GSIS reiterated its denial upon reconsideration, the case was forwarded to the Employees' Compensation Commission (ECC). The ECC, in a decision dated March 22, 1979, affirmed the GSIS's denial, concluding that the deceased's ailment was principally traceable to non-work-connected factors and not compensable under existing laws, specifically noting that the cause of liver cancer is generally unknown and often associated with factors like chronic alcohol ingestion and impaired nutrition. The Petition: Petitioner Milagros B. La O seeks review of the ECC's decision, arguing that her late husband's 28 years of government service and his eventual illness demonstrate that the disease was acquired during and in the course of his employment. She contends that hepatoma develops slowly and imperceptibly, suggesting the illness began years before its terminal manifestation, citing a record of absences for stomach trouble, fever, and flu between 1969 and 1974 as evidence of the ailment's early, unrecognized onset. Petitioner further argues that her husband's duties, which involved handling mutilated currency and irregular eating hours, likely aggravated his condition. She invokes prior rulings establishing a presumption of compensability for illnesses that supervene during employment, especially when the exact cause is unknown, and asserts that the cause of action accrued before the New Labor Code's effectivity, thus governing law should be the Workmen's Compensation Act. The petition also challenges the GSIS's assertion that it is not a proper respondent, arguing it is the ultimate implementing agency and a necessary party for enforcement.
Issue(s)
Whether the death of Perfecto V. La O due to hepatoma is compensable under the law, and what law governs the claim. Whether the presumption of compensability and the principle of aggravation under the Workmen's Compensation Act are applicable to the claim. Whether the GSIS is a proper party respondent in the petition for review.
Ruling
The Supreme Court set aside the decision of the Employees' Compensation Commission and ordered the Provincial Government of Quezon to pay the petitioner death benefits, refund medical and hospital expenses, and burial expenses. The Court ruled that the claim is compensable.
Ratio Decidendi
On the compensability of hepatoma and the applicable law: The Court held that while the GSIS and ECC denied the claim on the grounds that hepatoma was not principally work-connected and the claimant failed to prove increased risk or substantial contribution from working conditions, the claim accrued prior to the effectivity of the New Labor Code. Therefore, the governing law is the Workmen's Compensation Act, which presumes that an illness supervening during employment arose out of or was aggravated by such employment, shifting the burden of proof to the employer. The Court cited previous rulings, such as Corales vs. Employees' Compensation Commission, emphasizing that claims accruing before the New Labor Code are governed by the old law. The Court also noted that the nature of hepatoma is often insidious and its exact etiology unknown, making it difficult to pinpoint specific causes, thus reinforcing the application of the presumption of compensability. The Court further relied on precedents like Maria Cristina Fertilizer Corp. vs. WCC and Mercado vs. WCC, which held that cancer, even if not strictly occupational, can be deemed work-connected if working conditions likely affected the employee's health and reduced resistance, or if the illness supervened during employment and was aggravated by it. The Court stressed that it is not required for employment to be the sole factor; contribution to any degree is sufficient, and probability, not absolute certainty, is the test in compensation proceedings. The Court also pointed out that the ECC itself has expanded the list of occupational diseases to include certain types of cancer, acknowledging the work-relatedness of such ailments in specific contexts. On the presumption of compensability and aggravation: The Court reiterated that for claims accruing prior to the New Labor Code, the presumption of compensability and the principle of aggravation are applicable. This means that if an illness supervened during the course of employment, it is presumed to have arisen out of or been aggravated by the employment, unless the employer proves otherwise. The Court found that the respondents failed to establish proof to the contrary. The petitioner's record of absences due to stomach trouble, fever, diarrhea, and flu, coupled with the medical certificates indicating the ailment started six months prior with progressive abdominal pain, supported the claim that the illness manifested during employment and was aggravated by working conditions, such as handling mutilated bills and irregular eating times. The Court emphasized that the mere opinion of doctors regarding non-causality cannot prevail over the legal presumption when the cause of illness is not definitively determinable. On the GSIS as a proper party respondent: The Court held that the GSIS is a proper party respondent. Although the judicial review is of the ECC's decision, the GSIS is the ultimate implementing agency of the ECC's decisions and is involved in all aspects of employee compensation, including the enforcement of decisions. The Court's act of requiring the GSIS to comment further indicated its necessary participation in the proceedings.
Main Doctrine
Under the New Labor Code, for an illness not listed as an occupational disease to be compensable, the claimant must prove that the risk of contracting the ailment was increased by the working conditions or that the development of the ailment was largely brought about by the working conditions. However, for claims that accrued prior to the effectivity of the New Labor Code, the presumption of compensability and the principle of aggravation under the Workmen's Compensation Act apply, shifting the burden of proof to the employer.