Jacang v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Dionisio B. Jacang was employed as a janitor and later a factory worker. During his employment, he was diagnosed with pulmonary tuberculosis (PTB) in 1985, which worsened in 1987. He resigned from his job in 1990 due to his ailment. He was subsequently hospitalized and passed away on May 24, 1990. The cause of death listed on his certificate was Cardiopulmonary Arrest, with antecedent causes of DIC and underlying cause of Takayasu's Disease. Procedural History: The petitioner, Precy P. Jacang, filed a claim for death benefits with the Social Security System (SSS) on behalf of her deceased husband, Dionisio. The SSS denied the claim, stating there was no causal relation between Dionisio's death and his employment. The Employees' Compensation Commission (ECC) affirmed the SSS decision, noting that Takayasu's Disease is not an occupational disease and there was no evidence of increased risk due to his employment. The petitioner appealed to the Court of Appeals, which also denied her petition and subsequent motion for reconsideration. The Petition: This petition for review on certiorari seeks to overturn the Court of Appeals' decision. The petitioner argues that the appellate court erred by focusing solely on the death certificate and ignoring the circumstances surrounding Dionisio's death. She contends that Dionisio suffered from PTB, a compensable occupational disease, during his employment, and that this condition, or its aggravation, ultimately led to his death. The core issue is whether Dionisio's death is compensable under Presidential Decree No. 626, as amended, given the association between PTB and Takayasu's Disease, and the potential work-related factors contributing to his PTB.
Issue(s)
Whether the Court of Appeals gravely erred in dismissing the petition for review and denying the motion for reconsideration, and whether the Court of Appeals gravely erred in ignoring the circumstances surrounding the death of Dionisio Jacang by confining itself solely on the latter's Certificate of Death. Whether the death of Dionisio Jacang is compensable pursuant to P.D. No. 626, as amended.
Ruling
The Supreme Court reversed and set aside the assailed Court of Appeals Decision and Resolution. It ordered the respondent SSS to pay the petitioner her claim for compensation due to the death of her husband, Dionisio B. Jacang.
Ratio Decidendi
On the issues of the dismissal of the petition for review and the circumstances surrounding Dionisio Jacang's death: The Court held that the death of Dionisio Jacang is compensable under P.D. No. 626, as amended. While Takayasu's Disease, the underlying cause of death, is not listed as an occupational disease, it is scientifically linked to Pulmonary Tuberculosis (PTB), which is a listed occupational disease. The petitioner presented evidence that Dionisio had PTB during his employment, was physically fit before being hired, and that his ailment worsened during employment, leading to his resignation and eventual death. The Court noted that the SSS Accident/Sickness Report itself listed "Cardiopulmonary Arrest (PTB)" and the Report of Death mentioned "Pulmonary Tuberculosis, Renovascular Hypertension, secondary to Takayasu's Disease." On the issue of compensability under P.D. No. 626, as amended: The Court emphasized that even if the primary cause of death is a non-listed ailment, its association with a listed occupational disease is sufficient basis for compensation. Furthermore, the Court reiterated that P.D. No. 626 is a social legislation, and any doubt should be interpreted in favor of the employee. The Court found that substantial evidence was presented to show that Dionisio's ailment and death were associated with PTB, a compensable disease, and that factors inherent in his work, such as inhaling noxious gases and fumes, exposure to temperature changes, and fatigue, likely caused and aggravated his PTB. The Court found it unacceptable to deny benefits on the excuse of protecting the State Insurance Fund when the claim has a basis, as such strict protection might defeat the purpose of social justice legislation.
Main Doctrine
The death of an employee is compensable under P.D. No. 626, as amended, if the cause of death is an occupational disease listed in the Amended Rules on Employees Compensation, or if the illness is caused or precipitated by factors inherent in the employee's work and working conditions, with proof that the working conditions increased the risk of contracting the illness. Even if the primary cause of death is a non-listed disease, if it is associated with a listed occupational disease, compensation may still be granted, with any doubt to be interpreted in favor of the employee as P.D. No. 626 is a social legislation.