Godizano v. Employees’ Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Rosalinda Godizano is the wife of the deceased Enrique B. Godizano, a Philippine Navy officer. Enrique Godizano served in various capacities, including underwater operations, which involved retrieving drowned persons, lifeguard duties, salvage operations, and inspection of vessels. He sought medical consultation for pain and vomiting, later developing bipedal edema. He was diagnosed with acute renal failure secondary to chronic glomerulonephritis and hypertension. He succumbed to pulmonary edema and uremia secondary to chronic glomerulonephritis. Procedural History: Petitioner filed a claim for death benefits under P.D. 626, as amended, which was denied by the Government Service Insurance System (GSIS) on the ground that the sickness was not due to circumstances of employment. The GSIS later awarded permanent partial disability benefits for hypertension, recognizing it as a work-connected ailment, but not death benefits. The Employees’ Compensation Commission (ECC) affirmed the GSIS decision, ruling that the main ailment, glomerulonephritis, was not service-connected. The Petition: Petitioner sought review of the ECC decision, arguing that her husband's ailments could have developed as a result of his duties, including exposure to water and elements, and that he was in good health when he entered the service. The sole issue is whether the death of Enrique Godizano due to pulmonary edema and uremia secondary to chronic glomerulonephritis is compensable under P.D. 626, as amended.
Issue(s)
Whether the death of Philippine Navy Officer Enrique B. Godizano due to pulmonary edema and uremia secondary to chronic glomerulonephritis is compensable under P.D. 626, as amended, considering his working conditions. Whether the GSIS erred in granting permanent partial disability benefits instead of death benefits when the claim was explicitly for death benefits.
Ruling
The Supreme Court reversed the decision of the Employees’ Compensation Commission. It ordered the respondent Government Service Insurance System to pay the petitioner and her two children death benefits, funeral expenses, medical and hospital expenses, and attorney's fees. The Court ruled that the death was compensable and that the GSIS erred in awarding permanent partial disability benefits instead of death benefits.
Ratio Decidendi
On the compensability of death benefits: The Court held that the death of Enrique Godizano was compensable under P.D. 626, as amended. The definition of sickness under the law includes any illness caused by employment, subject to proof that the risk of contracting it is increased by working conditions. The deceased's duties, particularly underwater operations in potentially polluted waters of naval bases and South Vietnam, increased the risk of contracting infection-associated glomerulonephritis. The transition between water and land, and between different water temperatures, predisposed him to respiratory infections, which can cause glomerulonephritis. The Court found that the working conditions increased the risk of contracting the ailment, thus satisfying the requirement for compensability under the "increased risk" theory. The Court also clarified that pulmonary edema and uremia are complications of chronic glomerulonephritis, not separate ailments, and that the deterioration of the renal system leads to the failure of other vital systems. On the error of awarding permanent partial disability benefits instead of death benefits: The Court found that the GSIS erred in granting permanent partial disability benefits. The petitioner explicitly claimed death benefits, not disability benefits, as her husband was already deceased when the claim was filed. The Court emphasized that the contingency for which benefits were claimed was death, not disability. Furthermore, the Court noted that the computation of monthly income benefits should consider the effectivity of P.D. 1368, which occurred after the inception of the ailment but before the death of the employee, and applied P.D. No. 1146 for the computation of death benefits.
Main Doctrine
The death of a Philippine Navy officer due to pulmonary edema and uremia secondary to chronic glomerulonephritis is compensable under P.D. 626, as amended, when the risk of contracting the ailment is proven to have been increased by the working conditions.