Acosta v. Employees Compensation Commission
REITERATIONFacts
The Antecedents: Petitioners filed a claim for employees' compensation benefits for the death of Fe Acosta due to carcinoma of the ovary. The Government Service Insurance System (GSIS) denied the claim, stating the ailment was not casually related to the deceased's employment and thus outside the purview of the Employees Compensation Law. Procedural History: The deceased, a classroom teacher, began government service in 1949 and was assigned to Asingan Central School. In March 1978, she complained of lumbar pain and abdominal enlargement. She was diagnosed with "endometrioid carcinoma ovaries, stage III" in April 1978, leading to her retirement at age 51. She succumbed to the illness on October 2, 1978. The GSIS denied the claim, asserting the ailment was not occupational and her working conditions did not increase the risk of contracting it, citing hormonal influence, infection, and familial tendency as potential causes. The Employees Compensation Commission (ECC) affirmed the GSIS denial. The Petition: Petitioners appealed, arguing the deceased's duties included fieldwork (YCAP, Girl Scouts Camporals, barangay development program) exposing her to elements and weather, which lowered her resistance. They contended that ovarian cancer is akin to "rectal cancer," previously found compensable, and that the ECC's admission of unknown causes for ovarian cancer made its ruling illogical. They also questioned whether the attending physician's opinion could override the legal presumption of work-relatedness or aggravation. Petitioners argued that the GSIS's concession of possible aggravation created a causal relation and that the liberal interpretation of PD 626, as amended, particularly for "borderline cases," should apply.
Issue(s)
Whether the deceased's carcinoma of the ovary is compensable under Presidential Decree No. 626, as amended. Whether the deceased's out-of-campus activities and exposure to elements increased the risk of contracting the fatal disease. Whether the attending physician's opinion can override the presumption of work-relatedness or aggravation of an illness.
Ruling
The Supreme Court SET ASIDE the decision of the Employees Compensation Commission and DIRECTED the GSIS to pay petitioners P12,000.00 as death benefits and P1,200.00 as attorney's fees.
Ratio Decidendi
On whether the deceased's carcinoma of the ovary is compensable under Presidential Decree No. 626, as amended: The Court held that under PD 626, as amended, listed occupational diseases are compensable if conditions are met, and other diseases are compensable if the claimant proves increased risk due to working conditions. The claimant must show, by substantial evidence, that the job conditions largely contributed to the disease's development. While the GSIS initially denied the claim, its own comment suggested the ailment might have been aggravated by the deceased's work, creating an inconsistency. The Court noted that the Medical Officer admitted "infection" as a cause, and if the deceased's body resistance was lowered by work strain, she would be more susceptible to infection leading to the ailment. The Court invoked the policy of liberal interpretation of labor laws, citing Cristobal vs. ECC, to extend benefits, especially in "borderline cases," aligning with the State's policy of maximum aid and protection to labor. The Court found that petitioners substantially complied with the degree of proof required under the theory of increased risk, warranting favorable consideration. On whether the deceased's out-of-campus activities and exposure to elements increased the risk of contracting the fatal disease: The Court considered the petitioners' allegation that the deceased's duties included fieldwork and exposure to weather, which could have lowered her body resistance. Although the GSIS initially stated the ailment had no relation to the work except perhaps by way of aggravation, the Court found this concession significant. It reasoned that if aggravation arose, a causal relation between the work and the ailment exists, especially since the GSIS itself conceded the possibility of aggravation. The Court also noted that the Medical Officer identified "infection" as a cause, and lowered body resistance due to work strain could indeed increase susceptibility to infection, thus contributing to the ailment. On whether the attending physician's opinion can override the presumption of work-relatedness or aggravation of an illness: The Court addressed the issue of the attending physician's certification stating the illness was not caused by the employee's duties. It acknowledged that the exact origin of most cancers is still unknown, even to medical experts. Therefore, it would be illogical and contrary to the liberal interpretation of labor laws to expect ordinary claimants to prove the precise cause of such an ailment when experts are still uncertain. The Court emphasized that in compensation cases, the test for the relation between work and ailment is probability, not certainty. The Court also noted that the records did not show the exact date the deceased contracted the ailment, but it was discovered after the effectivity of the New Labor Code, further supporting a liberal construction in favor of the worker.
Main Doctrine
The claimant must show at least by substantial evidence that the development of the disease is brought largely by the conditions present in the nature of the job for it to be compensable under PD 626, as amended. However, a liberal interpretation in favor of the worker is applied, especially in borderline cases, considering the State's policy to give maximum aid and protection to labor.