Millora v. Employees' Compensation Commission
REITERATIONFacts
1. The Antecedents: Josefina Millora, widow of Prisco Millora, filed a claim for death benefits after her husband, a classroom teacher for nearly two decades, died at age 40. Prisco Millora had suffered from diabetes mellitus for eleven years prior to his death, requiring multiple hospitalizations for treatment of the disease and its complications, including diabetic ulcers and a cataract surgery. The death certificate listed the cause of death as infection following cataract extraction. 2. Procedural History: The claim for death benefits was initially denied by the Government Service Insurance System (GSIS). Upon denial, Josefina Millora appealed to the Employees' Compensation Commission (ECC). The ECC affirmed the GSIS's decision, dismissing the claim. This petition for review on certiorari to the Supreme Court followed the ECC's dismissal. 3. The Petition: This case is a petition for review on certiorari seeking to overturn the ECC's decision denying death benefits. The petitioner argues that while diabetes may be hereditary, the nature of her late husband's work as a teacher, involving long hours preparing lesson plans and participating in developmental projects, aggravated his condition and hastened his death. She contends that proof of direct causation is not necessary and that the risk of contracting the ailment was increased by his working conditions. The petitioner asserts that since the cause of diabetes is unknown and her husband had no predisposition, his work should be considered the cause.
Issue(s)
Whether the death of Prisco Millora is compensable under P.D. 626, as amended. Whether the principles of aggravation and presumption of compensability under the old Workmen's Compensation Act are still applicable under P.D. 626.
Ruling
The Supreme Court set aside the decision of the Employees' Compensation Commission and ordered the Government Service Insurance System to pay petitioner the sums of Twelve Thousand Pesos (P12,000.00) as death benefits, One Thousand Pesos (P1,000.00) as funeral expenses, and One Thousand and Two Hundred Pesos (P1,200.00) as attorney's fees.
Ratio Decidendi
On whether the death of Prisco Millora is compensable under P.D. 626, as amended: The Court found merit in the petitioner's contention that the nature of the deceased's work increased the risk of contracting diabetes mellitus and its complications. Prisco Millora, a public school teacher, worked long hours preparing lesson plans and instructional materials, and was involved in developmental projects. The Court cited Dr. Augusto Litonjua's opinion that stressful physical or emotional situations produce "contra-insulin" hormones, which increase blood sugar and can lead to diabetes. Given that the deceased was not predisposed by age, obesity, or heredity, and developed diabetes after eight years of employment, the Court concluded that his work situation could reasonably be described as physically and emotionally stressful, satisfying the endocrinal etiology of diabetes. Furthermore, the Court stated that these work activities also increased the deceased's risk of contracting the fatal complications, ulcer of the extremities and cataract. On whether the principles of aggravation and presumption of compensability under the old Workmen's Compensation Act are still applicable under P.D. 626: The Court clarified that these principles, which favored the employee, were abolished by the Labor Code (P.D. No. 626, as amended). The Court explained that these innovations "paved the way for the latitudinarian or expansive application of the Workmen's Compensation Law in favor of the employee or worker," which was found to be unsatisfactory as it "destroyed the parity or balance between the competing interests of employer and employee." To restore equilibrium, the old law was replaced by the employees' compensation and state insurance fund in the Labor Code. Therefore, under the Labor Code, the presumption of compensability and the rule on aggravation of illness are no longer applicable, and the Court is powerless to apply them. The law now requires that the illness or death must be an occupational disease listed by the Commission or caused by employment, with proof that the risk of contracting it is increased by working conditions.
Main Doctrine
Under the Labor Code, as amended (PD 626), the presumption of compensability and the rule on aggravation of illness caused by the nature of employment, which were available under the Workmen's Compensation Act, were abolished. To be entitled to sickness or death benefits, the illness or death must be an occupational disease listed by the Commission or caused by employment, with proof that the risk of contracting it is increased by working conditions.