Casumpang v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: The underlying dispute concerns a claim for death benefits filed by Gliceria C. Casumpang, the widow of the late Jose Casumpang. Jose Casumpang, a Prison Guard at the Bureau of Prisons, died from cancer of the stomach. His widow sought compensation for his death, asserting that his illness was work-related. Procedural History: The claim was initially filed by Jose Casumpang and, following his death, was pursued by his widow, Gliceria Casumpang. The Government Service Insurance System (GSIS) denied the claim, stating that the cause of death was not an occupational disease and that the evidence did not establish a causal relationship between his occupation as a Prison Guard and his illness. The Employees' Compensation Commission (ECC) affirmed the GSIS's decision, finding that the evidence did not prove that the risk of contracting gastric carcinoma was increased by the deceased's working conditions. The widow then appealed this decision. The Petition: This case comes before the Supreme Court on a petition for review of the ECC's decision. The petitioner argues for the compensability of her husband's death due to stomach cancer. The core issue is whether cancer of the stomach is an occupational disease compensable under Presidential Decree No. 626, as amended, which is the applicable law given that the ailments manifested after January 1, 1975. The petitioner contends that the presumption of compensability under the old Workmen's Compensation Act should apply, while the respondents argue that under the current law, proof of causation is imperative and that stomach cancer is not listed as an occupational disease for prison guards, nor has the petitioner demonstrated that the specific working conditions increased the risk of contracting the disease.
Issue(s)
Whether cancer of the stomach is an occupational disease and hence compensable under Presidential Decree No. 626, as amended. Whether the presumption of compensability under the old Workmen's Compensation Act applies to the claim.
Ruling
The petition is DISMISSED. The decision of the Government Service Insurance System and the Employees' Compensation Commission denying the claim are AFFIRMED.
Ratio Decidendi
On whether cancer of the stomach is an occupational disease and hence compensable under Presidential Decree No. 626, as amended: The Court affirmed the ECC's ruling that cancer of the stomach is not an occupational disease for a prison guard under Presidential Decree No. 626, as amended. The Court noted that under the said law, for a sickness to be compensable, it must be an occupational disease listed in Annex "A" of the Rules, or proof must be shown that the risk of contracting the disease is increased by the working conditions. The Court agreed with the Solicitor General that cancer of the stomach was considered occupational only among specific industries like woodworkers, carpenters, loggers, and employees of pulp and paper mills. Furthermore, the Court found that the conditions of the deceased's employment, such as escorting inmates, working in the hinterlands, working at night, and missing meals, did not establish a direct causal connection with the development of cancer of the stomach. The GSIS had previously found that the submitted evidence was insufficient to establish that the ailment was a direct result of the occupation. On whether the presumption of compensability under the old Workmen's Compensation Act applies to the claim: The Court held that the presumption of compensability, which was expressly provided under the old Workmen's Compensation Act (Act 3428), is not recognized under Presidential Decree No. 626, as amended. The new law requires proof of causation by the claimant, which is incompatible with the presumption of compensability. The Court clarified that the doctrine of presumptive compensability was stricken off by the lawmaker under the new law. Therefore, the petitioner could not rely on the argument that compensability is presumed once the ailment is shown to have supervened in the course of employment. The Court also noted that the deceased's ailments all occurred after January 1, 1975, the effectivity date of the Labor Code, making Presidential Decree No. 626, as amended, the applicable law, not the Workmen's Compensation Act. The case of Aninias v. Workmen's Compensation Commission was distinguished as it applied the old law.
Main Doctrine
Under Presidential Decree No. 626, as amended, the presumption of compensability and the principle of aggravation of illness by reason of employment, as provided under the old Workmen's Compensation Act, are no longer recognized. Proof of causation by the claimant is imperative for an illness to be considered compensable.