Kirit v. Government Service Insurance System
REITERATIONFacts
The Antecedents: The late Eugenia A. Kirit, a classroom teacher, was diagnosed with "Osteoarthritis and Giant Cell Tumor, left humerus" after being confined for pain and numbness. She died on July 1, 1976. Procedural History: A claim for death benefits under Presidential Decree No. 626, as amended, was filed with the Government Service Insurance System (GSIS). The GSIS denied the claim, stating that osteoarthritis and giant cell tumor are not occupational diseases and were not shown to have directly resulted from the decedent's occupation. The Employees' Compensation Commission (ECC) affirmed the GSIS denial, noting that these ailments are not on the list of occupational diseases and are generally considered results of aging or precipitated by extrinsic factors unrelated to employment. The Petition: Petitioners sought a review of the ECC's decision, arguing for the compensability of the death benefits.
Issue(s)
Whether the death of Eugenia Kirit caused by osteoarthritis and/or giant cell tumor is legally compensable under Presidential Decree No. 626, as amended. Whether the presumptions of compensability and aggravation under the former Workmen's Compensation Act apply to claims filed under the Labor Code.
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 whether the death of Eugenia Kirit caused by osteoarthritis and/or giant cell tumor is legally compensable under Presidential Decree No. 626, as amended: The Court held that for a sickness or resulting disability or death to be compensable under Article 167(1) of the Labor Code, as amended, the claimant must establish either that the illness is an occupational disease listed by the Employees' Compensation Commission (ECC) or that the risk of contracting the illness is increased by the working conditions. In this case, osteoarthritis and giant cell tumor are not listed as occupational diseases by the ECC. The petitioners failed to present any evidence to prove that the decedent's working conditions as a teacher increased the risk of her contracting these fatal illnesses. They relied solely on the theory of aggravation and presumptions under the old compensation law, which are no longer applicable. Therefore, the claim was correctly denied. On whether the presumptions of compensability and aggravation under the former Workmen's Compensation Act apply to claims filed under the Labor Code: The Court reiterated that the provisions of the Labor Code apply to cases where the illness and death occurred after January 1, 1975. The presumptions of compensability and aggravation provided under the former Workmen's Compensation Act were abandoned under the compensation scheme in the present Labor Code. Awards of compensation benefits can no longer rest on presumptions but require a showing that the causative disease is listed by the ECC or substantial evidence that the risk of contracting the disease is increased by the employees' working conditions. Petitioners' reliance on these abandoned presumptions was misplaced.
Main Doctrine
Under the Labor Code, for a sickness or resulting disability or death to be compensable, the claimant must show that it is either an occupational disease listed by the Employees' Compensation Commission (ECC) or, if not listed, that the risk of contracting the same is increased by working conditions. Presumptions of compensability under the former Workmen's Compensation Act are no longer applicable.