Government Service Insurance System v. Fontanares
REITERATIONFacts
The Antecedents: The respondent, Benjamin Nonoy O. Fontanares, filed a claim for compensation, income, and hospitalization benefits with the Government Service Insurance System (GSIS) due to Rheumatic Heart Disease and Pulmonary Tuberculosis Minimal. Fontanares began his government service in 1987 and held positions such as Storekeeper I, Archivist I, and Maritime Industry Development Specialist II. His duties involved processing documents, retrieving records, preparing correspondence, sorting archival materials, preparing technical reports, and inspecting ships. He was confined in January 1998 due to Rheumatic Valvular Disease with AS, MR, Cardiomyopathy and PTB Minimal, with subsequent chest x-rays showing findings consistent with PTB and Cardiomegaly. Procedural History: The GSIS initially awarded temporary total disability benefits for the period of confinement but denied the claim for compensation related to Rheumatic Heart Disease, deeming it not work-connected. Dissatisfied, Fontanares elevated his case to the Employees’ Compensation Commission (ECC). On August 19, 1999, the ECC affirmed the GSIS decision, holding that Rheumatic Heart Disease is not a compensable ailment under Presidential Decree (P.D.) No. 626, as amended, and that Fontanares failed to prove that his working conditions increased the risk of contracting the disease or that there was a causal relation between his ailment and his work. Fontanares then appealed to the Court of Appeals (CA) under Rule 43 of the Rules of Court. The Petition: The GSIS filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the February 6, 2001 Decision of the Court of Appeals, which reversed the ECC's decision and declared Rheumatic Heart Disease compensable. The GSIS argues that the CA erred in awarding compensation benefits without a showing that Fontanares' working conditions increased the risk of contracting Rheumatic Heart Disease and questions whether the illness is compensable when it is not explicitly listed under P.D. No. 626, as amended. The GSIS contends that Fontanares failed to discharge his burden of proof by substantial evidence to establish a causal relation between his employment and his illness, and that the CA erred in presuming compensability simply because the illness supervened during employment, disregarding the shift in legal framework under P.D. No. 626, as amended.
Issue(s)
Whether the Court of Appeals erred in declaring respondent entitled to compensation benefits even though there was no showing that his working conditions had increased the risk of his contracting Rheumatic Heart Disease. Whether the illness Rheumatic Heart Disease is compensable when such disease is clearly not included in the list of compensable diseases under PD 626, as amended.
Ruling
The petition is GRANTED. The Decision and Resolution of the Court of Appeals are REVERSED and SET ASIDE. The Decision of the Employees Compensation Commission dated August 19, 1999 is AFFIRMED.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in declaring respondent entitled to compensation benefits despite no showing that his working conditions increased the risk of contracting Rheumatic Heart Disease: The Court held that the respondent failed to discharge his burden of proof, under the measure of substantial evidence, that his working conditions increased the risk of contracting Rheumatic Heart Disease. The records lacked medical information establishing the etiology of Rheumatic Heart Disease to evaluate a causal relation between the respondent's employment and his illness. The Certifications from the Department of Health, while indicating exposure to chemical and biological hazards, were for the purpose of hazard pay and specific years, and did not establish a causal link to Rheumatic Heart Disease. The Court reiterated that under PD 626, as amended, the claimant must prove that the risk of contracting the disease was increased by working conditions and that there is a causal relation between the ailment and working conditions. On the issue of whether Rheumatic Heart Disease is compensable when not included in the list of compensable diseases under PD 626, as amended: The Court affirmed that Rheumatic Heart Disease is not listed as an occupational disease under PD 626, as amended. Therefore, the claimant must prove the increased risk and causal relation. The Court noted that Rheumatic Heart Disease is either a result of or ascribed to previous rheumatic fever, and other etiologies exist. The respondent failed to prove that his work conditions had predisposing factors that caused Rheumatic Fever, which in turn led to Rheumatic Heart Disease. Exposure to toxic chemicals and biological hazards does not, by itself, constitute the cause of the ailment. The respondent also failed to present evidence of contracting Rheumatic Fever. The Court emphasized that the presumption of compensability and aggravation under the prior law was discarded by PD 626, as amended, requiring claimants to prove causation by substantial evidence.
Main Doctrine
Under Presidential Decree No. 626, as amended, for an illness not listed as an occupational disease to be compensable, the claimant must prove by substantial evidence that the risk of contracting the disease was increased by the claimant's working conditions and that there is a causal relation between the ailment and the working conditions. The presumption of compensability and aggravation under the prior law has been discarded.