GSIS vs RAOET Facts: Respondent’s husband, Francisco, Francisco, worked in the government service as an Engineer Engineer A at NIA, Francisco supervised supervised the implementation implementation of construction construction activities of Lateral E and E!" #e was also tasked to review and check the structural plan and the facilities" In $%%%, Francisco was diagnosed with Hypertension, Severe, Stage III, Coronary Artery Disease, and Disease, and he was confined" As the &'I' considered this a workrelated condition, Francisco was awarded awarded (% da)s da)s *emporar) mporar) *otal +isabilit +isabilit) ) benefit benefits, s, plus plus reimburs reimbursemen ementt of medical medical epenses incurred during treatment" In $%%!, Francisco Francisco was rushed rushed to the hospital hospital because because he was was vomiting blood" blood" #e was pronounced pronounced dead on arrival at the hospital" #is death certificate listed listed the causes of his death as follows- .A/'E' 0F +EA*# Immediate cause- .ardiac Arrest Antecedent Antecedent causecause- Acute Acute 1assive 1assive #emorrhage #emorrhage /nderl)ing cause- *2. 3leeding 4eptic /lcer +isease *he respondent, as widow, filed with the &'I' a claim for income benefits accruing from the death of her husban husband, d, pursuant pursuant to P.D. 626 , as amended" &'I' denied the claim on the ground that the respondent did not submit an) supporting documents to show that Francisco’s death was due to peptic ulcer" 0n appeal, the E.. affirmed the findings of the &'I'" Respondent elevated the case to the .A through a 4etition for Review" .A reversed the E.. decision, held that while the Amended Rules on Emplo)ees’ .ompensation does not list peptic ulcer as an occupational disease, Francisco’s death should be compensable since its immediate cause was cardiac arrest" Issue: !" 5heth 5hether er or or not not the ailmen ailmentt Acute Massive Massive Hemorrhage Hemorrhage t/c !ee"ing !ee"ing Peptic Peptic #!cer #!cer Disease, which Disease, which caused the death of the late Francisco, is workconnected or whether there was an) proof to show that the risk of contracting the same was increased b) factors attendant to his emplo)ment" $" +id Francisco’s Francisco’s occupation occupation involve prolonged prolonged emotional emotional or ph)sical ph)sical stress stress to make his his death due to peptic ulcer compensable6
Held: 1. 7es, 7es, 4"+" 8$8, 8$8, as amended amended,, defines defines compens compensable able sickness sickness as 9an) 9an) illness illness definit definitel) el) accepted as an occupational disease listed b) the .ommission, or an) illness caused b) emplo)me emplo)ment nt sub:ect to proof proof b) the emplo)e emplo)ee e that the risk of contracting contracting the same is increased b) the working conditions"9 'ection ! ;b<, Rule III of the Amended Rules on Emplo)ees= .ompensation implements 4"+" "+" 8$8 and re>uires that for sickness and the resulting disabilit) or death to be compensable, compensable,
it must be an 9occupational disease9 included in the list provided ; Anne$ %A% < , with the conditions attached to the listed sickness dul) satisfied? otherwise, the claimant must show proof that the risk of contracting the illness is increased b) his working conditions" In plainer terms, to be entitled to compensation, a claimant must show that the sickness is either ;!< a result o an occu!ational disease listed under Anne" #A# of the Amended Rules on Emplo)ees= .ompensation under the conditions Anne" $A% sets orth ? or ;$< if not so listed, that the risk o contractin& the disease is increased '( the workin& conditions " Respondent submitted sufficient proof of the cause of her husband’s death when she presented his death certificate" )eath certiicates and the notes b) a municipal health officer prepared in the regular performance of his duties are prima facie evidence o acts therein stated" A dul(*re&istered death certiicate is considered a !u'lic document and the entries ound therein are !resumed correct , unless the part) who contests its accurac) can produce positive evidence establishing a contrar) conclusion" and it esta'lishes the act o death and its immediate+ antecedent+ and underl(in& causes " 'ince neither the &'I' nor the E.. presented an) evidence to refute that cardiac arrest was the immediate cause, and peptic ulcer was the underl)ing cause of Francisco’s death, we accept as established, in accordance with the death certificate, that the underl)ing cause of Francisco’s demise was peptic ulcer" *he .A is apparentl) wrong in its conclusion as it viewed in isolation the immediate cause of death ;cardiac arrest<, disregarding that what brought about the cardiac arrest was the ultimate underl)ing cause @ peptic ulcer" .ontrar) to the .A’s conclusion, peptic ulcer is a compensable cause of death, pursuant to E.. Resolution No" !88, which unmistakabl) provides that !e!tic ulcer is a com!ensa'le disease listed under Anne" $A,B provided the claimant is in an occu!ation that involves !rolon&ed emotional or !h(sical stress , as among !roessional !eo!le, transport workers and the like" Peptic #!cer is defined asCADn ulceration of the mucous membrane of the esophagus, stomach or duodenum, caused b) the action of the acid gastric :uice" 4eptic ulcer is most common amon& !ersons who are chronicall( an"ious or irritated+ or who otherwise suer rom mental tension " It occurs about three times as often in men as in women" ')mptoms include a pain or gnawing sensation in the epigastric region" *he pain occurs from ! to ( hours after eating, and is usuall) relieved b) eating or taking an antacid drug" omiting, sometimes preceded b) nausea, usuall) follows a severe bout of pain" .014LI.A*I0N'" If ulcers are untreated, bleeding can occur, leading to anemia and therefore weakness and impaired health" ,lood ma( 'e vomited+ and a!!ears 'rownish and like coee &rounds because of the digestive effect of gastric secretions on the hemoglobin" *here ma) be blood in the stools, giving them a tarr) black color . In acute cases sudden hemorrha&e can occur and ma( 'e atal i not treated !ro!erl( "
-orr( and an"iet( can contri'ute to the develo!ment o an ulcer and !revent it rom healin&" If emotional tensions persist, an ulcer that has been healed b) medical treatment can return" *herefore, ever) effort is made to help the patient rela" 'ometimes counseling or ps)chotherap) is helpful in relieving emotional strain"
. 7es" Francisco was diagnosed with Hypertension, Severe, Stage III, Coronary Artery Disease, and confined at the #ospital in $%%%" *he &'I' found this ailment workconnected and awarded Francisco (% da)s *emporar) *otal +isabilit) benefits" It was established when &'I' acknowledge and awarded total temporar) disabilit) that the underl)ing causes of the combination of these diseases are, among others, the stressul nature and !ressures inherent in an occu!ation. Francisco worked as Engineer A with the NIA, a :ob with enormous responsibilities" #e had to supervise the construction activities and review the structural plan and facilities" *he stresses these responsibilities carried did not abate for Francisco when he returned from his *emporar) *otal +isabilit)? he occupied the same position without change of responsibilities until his death" *hus, Francisco had continuous eposure to prolonged emotional stress that would >ualif) his peptic ulcer @ a stress driven ailment @ as a compensable cause of death"
In determining the compensabilit) of an illness, we do not re>uire that the emplo)ment be the sole factor in the growth, development, or acceleration of a claimant’s illness to entitle him to the benefits provided for" It is enough that his emplo)ment contributed, even if onl) in a small degree, to the development of the disease" It is wellsettled that the degree of proof re>uired under 4"+" No" 8$8 is merel) substantial evidence, which means, such relevant evidence as a reasonable mind might accept as ade>uate to support a conclusion"B -hat the law re/uires is a reasona'le work*connection and not a direct causal relation " It is enough that the h)pothesis on which the workman’s claim is based is probable" 1edical opinion to the contrar) can be disregarded especiall) where there is some basis in the facts for inferring a work connection" 0ro'a'ilit(+ not certaint(+ is the touchstone. It is not re/uired that the em!lo(ment 'e the sole actor in the &rowth+ develo!ment or acceleration o a claimants illness to entitle him to the 'eneits !rovided or. It is enou&h that his em!lo(ment contri'uted+ even i to a small de&ree+ to the develo!ment o the disease. 4"+" 8$8 as a social legislation whose primordial purpose is to provide meaningful protection to the working class against the haGards of disabilit), illness, and other contingencies resulting in loss of income" In emplo)ee compensation, persons charged b) law to carr) out the .onstitution’s social :ustice ob:ectives should adopt a liberal attitude in deciding compensabilit) claims and should not hesitate to grant compensabilit) where a reasonable measure of work connection can be inferred" 0nl) this kind of interpretation can give meaning and substance to the law’s compassionate spirit as epressed in Article H of the Labor .ode @ that all doubts in the implementation and interpretation of the provisions of the Labor .ode, including their implementing rules and regulations, should be resolved in favor of labor "C$%D 5hen the implementors fail to reach up to these standards, this .ourt, as guardian of the .onstitution, necessaril) has to take up the slack and order what we must, to ensure that the constitutional ob:ectives are achieved"
