Santos v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner's husband, Francisco Santos, was employed as a welder at the Philippine Navy for 32 years. He was admitted to the hospital with epigastric pain and vomiting blood, diagnosed with bleeding Peptic Ulcer disease, cholelithiasis, and diabetes mellitus. He died on January 11, 1987, with liver cirrhosis indicated as the cause of death. Procedural History: Petitioner filed a claim for death benefits under Presidential Decree No. 626, as amended. The Government Service Insurance System (GSIS) denied the claim, stating that Francisco's ailment was not an occupational disease. The Commander of NASCOM, PN, endorsed the claim, detailing Francisco's exposure to heat, gas fumes, and chemical substances from welding, particularly within enclosed compartments. The GSIS maintained its denial, suggesting welding causes lung disease, not liver cirrhosis. The Employees' Compensation Commission (ECC) affirmed the denial, noting the death certificate did not specify the type of cirrhosis, although it acknowledged the deceased had no history of alcoholism or hepatitis. The Petition: Petitioner sought review of the ECC's decision, arguing that her husband's death due to liver cirrhosis was compensable given his working conditions as a welder.
Issue(s)
Whether liver cirrhosis is a compensable sickness under Presidential Decree No. 626, as amended, and the general principles for determining compensability. Whether the risk of contracting liver cirrhosis was increased by the working conditions of the deceased as a welder, considering his exposure to harmful substances and the duration of his employment.
Ruling
The petition is granted. The decision of the Employees' Compensation Commission is reversed. Liver cirrhosis is considered compensable in this case on the ground that the nature of the petitioner's husband's work exposed him to the risk of contracting the same.
Ratio Decidendi
On Whether liver cirrhosis is a compensable sickness under Presidential Decree No. 626, as amended, and the general principles for determining compensability: The law defines compensable sickness as an illness listed as an occupational disease or any illness caused by employment where the risk of contracting it is increased by working conditions. Cirrhosis of the liver is not explicitly listed as an occupational disease. However, the Court has previously taken a liberal stance in cases of liver cirrhosis, such as in Librea v. Employees' Compensation Commission, where a similar claim was granted. The Court acknowledged that while it is not a medical expert, it cannot discount the possibility that the cause of death could be related to working conditions, especially when the Commission itself theorized that post-necrotic cirrhosis can be caused by toxins. On Whether the risk of contracting liver cirrhosis was increased by the working conditions of the deceased as a welder, considering his exposure to harmful substances and the duration of his employment: As a welder for 32 years, Francisco Santos was exposed to heat, gas fumes, and chemical substances from burning electrodes, including carbon monoxide, carbon dioxide, sulfur, and phosphorus, particularly when performing welding jobs inside enclosed compartments. Research indicates that prolonged inhalation or ingestion of such substances can lead to industrial hazards like siderosis and liver failure. The Court found that Francisco's continuous exposure to these elements over 32 years would likely cause poisoning and malfunction of the liver. This aligns with the principle that if an illness is not listed as occupational, the claimant must prove that the risk of contracting it was increased by the working conditions. The Court emphasized that while the presumption of compensability under the old Workmen's Compensation Act was abolished, the liberality of the law in favor of the working man still prevails, and all doubts in the implementation and interpretation of the Labor Code should be resolved in favor of labor, as mandated by Article 4 of the New Labor Code.
Main Doctrine
Liver cirrhosis, though not listed as an occupational disease, may be compensable if the claimant proves that the risk of contracting the disease was increased by the working conditions, consistent with the liberal interpretation of social legislation in favor of labor.