Tañedo v. Employees Compensation Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for death benefits filed by Angelita Tañedo, the widow of Francisco Tanedo, a Janitor-Laborer at the Ministry of Agrarian Reform. Francisco Tanedo died from what was diagnosed as renal insufficiency secondary to chronic renal disease, with complications including renal hypertension and Koch's pulmonary. The petitioner sought benefits under P.D. No. 626, as amended. 2. Procedural History: The petitioner's claim for death benefits was initially denied by the Government Service Insurance System (GSIS) on the grounds that the primary cause of death, chronic glomerulonephritis, was not a listed compensable illness under the law. The GSIS also rejected the claim that renal hypertension and Koch's pulmonary were the effective causes or were work-related. The petitioner's motion for reconsideration was denied, and she subsequently appealed to the Employees' Compensation Commission (ECC). The ECC affirmed the GSIS's decision, leading to the current petition before the Supreme Court. 3. The Petition: The petitioner seeks a reversal of the decisions made by the GSIS and the ECC, praying for the award of death benefits. The core of her argument hinges on the assertion that her husband's death was caused by renal hypertension and Koch's pulmonary, and that the risk of contracting these conditions was increased by his working conditions as a janitor-laborer. She is petitioning the Supreme Court to review the denial of these benefits.
Issue(s)
Whether the illness causing the death of Francisco Tanedo is compensable under P.D. No. 626, as amended. Whether the presumption of compensability under the old Workmen's Compensation Act still applies.
Ruling
The petition is dismissed. The decisions of the Employees Compensation Commission and the Government Service Insurance System denying the claim for death benefits are affirmed.
Ratio Decidendi
On whether the illness is compensable: The Court reiterated that for an illness to be compensable under P.D. 626, as amended, the claimant must show that it is either an occupational disease listed by the Commission or that the risk of contracting the disease is increased by the working conditions. The Court noted that "chronic glomerulonephritis" is not among the listed compensable illnesses in Annex "A" of the Amended Rules on Employees Compensation. The petitioner failed to adduce substantial evidence to prove that the risk of contracting the diseases (glomerulonephritis, renal hypertension, and Koch's pulmonary) was increased by her husband's working conditions. The Court found that the hypertension was merely a complication of the chronic glomerulonephritis and not brought about by employment factors. The evidence established that the disease and its complications bore no causal relation to the nature of his employment. On the applicability of the presumption of compensability: The Court clarified that the presumption of compensability laid down by the old statute (Sec. 43, Act 3428, Workmen's Compensation Act) is no longer applicable. This presumption was abolished upon the effectivity of the new law on January 1, 1975. Awards of compensation benefits can no longer rest on presumption but require a showing that the causative disease is listed by the ECC or that the risk of contracting the disease is increased by the employee's working conditions, supported by substantial evidence.
Main Doctrine
For an illness to be compensable under P.D. 626, as amended, the claimant must prove either that it is an occupational disease listed by the Commission or that the risk of contracting the disease is increased by the working conditions. The presumption of compensability under the old law is no longer applicable.