Sarmiento v. Employees' Compensation Commission
REITERATIONFacts
1. The Antecedents: The late Flordeliza Sarmiento, employed by the National Power Corporation, was diagnosed with "differentiated squamous cell carcinoma" in April 1980. Her condition worsened, leading to a soft tissue mass on her cheek, deformed lips, and inability to close her eye. She succumbed to cardiorespiratory arrest due to parotid carcinoma on August 12, 1981, at the age of 40. 2. Procedural History: The surviving spouse filed a claim for death benefits under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, stating that parotid carcinoma is not caused by employment conditions. The Employees' Compensation Commission (ECC) affirmed the GSIS decision, finding that the death causation by parotid carcinoma was not compensable as it was not contracted by reason of work but by reason of embryonic rests and epithelial growth. 3. The Petition: The petitioner sought a review of the ECC decision, arguing for the compensability of the deceased's illness. He also attacked the constitutionality of Presidential Decree No. 626, as amended, alleging it infringes upon social justice, due process, and equal protection, and prayed for the application of the old Workmen's Compensation Act with its presumption of compensability.
Issue(s)
Whether Presidential Decree No. 626, as amended, is constitutional. Whether the death of Flordeliza Sarmiento due to parotid carcinoma is compensable under Presidential Decree No. 626, as amended.
Ruling
The petition is DISMISSED. The decisions of the Government Service Insurance System and the Employees' Compensation Commission denying the claim are AFFIRMED.
Ratio Decidendi
On the constitutionality of Presidential Decree No. 626, as amended: The Court dismissed the petitioner's challenge to the constitutionality of Presidential Decree No. 626, as amended. It noted that the petitioner filed his claim under this very law and only questioned its constitutionality upon rejection. The Court reiterated its recognition of the validity of the new law, which discarded the concepts of "presumption of compensability" and "aggravation" to establish a "sensible equilibrium" between employer obligations and employee rights. The new scheme, as explained in De Jesus v. Employees' Compensation Commission, operates as a state insurance fund built by employer contributions, with a neutral ECC determining claims based on supporting papers and medical evidence, ensuring prompt payment and lower administration costs. The Court emphasized that the wisdom of the present scheme is a matter for the President and Congress, and its duty is to apply the law as it stands. On the compensability of the illness: The Court affirmed the denial of the claim, finding no proof that the deceased's working conditions caused or increased the risk of her contracting parotid carcinoma. Under the present law, a compensable illness must be an occupational disease listed by the ECC or proven to be caused by employment, with the risk increased by working conditions. Parotid carcinoma was not an occupational disease given the deceased's employment as an accounting clerk and budget manager. The petitioner's allegations that field trips and air travel caused the illness were deemed mere conjectures. Medical evaluations indicated that the cause and nature of parotid carcinoma are not fully known, with potential causes including dehydration, poor oral hygiene, or metastatic lesions, none of which were linked to the deceased's employment conditions. Therefore, the findings of the public respondents that the deceased's working conditions did not cause or increase the risk of her illness were upheld.
Main Doctrine
Under Presidential Decree No. 626, as amended, an illness is compensable if it is an occupational disease listed by the Employees' Compensation Commission or if it is caused by employment, with the employee proving that the risk of contracting the illness was increased by working conditions. The presumption of compensability and the concept of aggravation under the old Workmen's Compensation Act were discarded.