De Leon v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Diosa de Leon is the widow of Ruben de Leon, an employee of the Philippine Navy who worked as an electrician and repairman for 23 years. During his employment, Ruben de Leon was treated for acute tonsillitis in 1969 and pulmonary tuberculosis in 1975 and from 1976 to 1978. On May 25, 1978, he was confined and diagnosed with carcinoma of the nasopharynx, metastatic to lymph node. He succumbed to the illness on September 5, 1978, at the age of 43. Procedural History: Petitioner filed a claim for death benefits under Presidential Decree No. 626 with the Philippine Navy, which was transmitted to the Government Service Insurance System (GSIS). The GSIS denied the claim, stating that the sickness was not due to circumstances of employment. Petitioner's motion for reconsideration was also denied. The Employees' Compensation Commission (ECC) affirmed the GSIS decision, holding that nasopharyngeal carcinoma is not an occupational disease and its cause is unknown, developing independently of employment. The ECC also noted that it is a "tumor of youth" occurring more often below the age of thirty. The Petition: Petitioner filed a petition for certiorari with the Supreme Court, seeking to set aside the decision of the ECC.
Issue(s)
Whether the death of Ruben de Leon from carcinoma of the nasopharynx is compensable under Presidential Decree No. 626. Whether the ailment of the deceased was aggravated by his employment as an electrician in the Philippine Navy.
Ruling
The Supreme Court set aside the decision of the respondent Employees' Compensation Commission and ordered the Government Service Insurance System to pay the petitioner death benefits, refund medical and hospital expenses, burial expenses, and attorney's fees.
Ratio Decidendi
On the issue of compensability of carcinoma of the nasopharynx: The Court reiterated its ruling in Dator v. ECC that until the cause of cancer is known, it should be considered compensable, especially when the risk of contracting it is increased by working conditions. The Court found it plausible that the deceased's prior treatments for acute tonsillitis and pulmonary tuberculosis, coupled with his work involving exposure to chemicals from welding and batteries, could have contributed to the development or aggravation of the nasopharyngeal carcinoma. The Court noted that symptoms of one ailment can be mistaken for another, and that bronchial carcinoma can be mistaken for pulmonary tuberculosis. The Court also considered the possibility that the deceased's ailment was contracted as early as 1969, thus falling under the more beneficial provisions of the old Workmen's Compensation Act. On the issue of aggravation by employment: The Court found that the deceased's duties as an electrician, involving constant inhalation of and exposure to obnoxious chemicals from batteries, welding, and electrical devices, likely hastened the physical weakening of his body, rendering him more susceptible to diseases. Even if the ailment was not directly caused by employment, the Court held that it was at the very least aggravated by his employment. The Court emphasized that the nature of cancer is often insidious and detected only in advanced stages, and that the deceased's initial physical fitness for employment did not preclude subsequent aggravation of a condition due to his work. The Court cited Cristobal v. ECC and Bihag v. WCC to support the view that the exact etiology of cancer is unknown and that irritation from chemical, mechanical, or thermal stimuli can contribute to its development. The Court concluded that all doubts should be resolved in favor of the employee, consistent with the constitutional guarantee of social justice.
Main Doctrine
The Court reiterated that while the exact etiology of cancer remains unknown, certain types of cancer, including nasopharyngeal carcinoma, may be considered compensable under the law if there is proof that the risk of contracting the disease is increased by the employee's working conditions, or if the ailment was aggravated by employment. The Court also emphasized the liberal interpretation of labor laws in favor of the employee, especially when dealing with unknown etiologies of diseases like cancer.