Facts:

The case involves petitioner Teresa M. Armena who filed for a review by certiorari regarding the decision made by the Employees' Compensation Commission (ECC) and the Government Service Insurance System (GSIS). The events leading to the case began on June 1, 1976, when Patricio D. Armena, the petitioner’s husband, passed away due to "acute monocytic leukemia." Patricio was a government employee from February 21, 1942, holding various positions including clerk, public school teacher, budget examiner, and ultimately serving as the municipal treasurer of Daraga, Albay from July 1, 1975, until his death. Following his death, Teresa filed a claim for employee compensation on September 30, 1976. However, the GSIS denied her claim, arguing that Patricio's ailment was not causally related to his work and was not an occupational disease as defined by existing law. Furthermore, Teresa's motion for reconsideration was also denied. She appealed this decision to the ECC

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Facts:

Background of Employment and Death

• Petitioner Teresa M. Armena filed a claim for death benefits following the death of her husband, Patricio D. Armena.
• Patricio D. Armena was a government employee who held various positions, notably serving as a municipal treasurer of Daraga, Albay from July 1, 1975 until his death on June 1, 1976.
• His service record also included roles as clerk, public school teacher, and budget examiner, evidencing a long and varied career in government service.

Circumstances Surrounding the Death

• The cause of death was certified as "acute monocytic leukemia," a form of blood cancer characterized by the uncontrolled proliferation of monocytic cells in the bone marrow, liver, and spleen.
• The illness, while diagnosed and treated following several hospitalizations for allergy, influenza, and urinary tract infections, was ultimately deemed fatal.

Filing and Denial of the Claim

• On September 30, 1976, petitioner Teresa M. Armena filed a claim for employee’s compensation with the Government Service Insurance System (GSIS) for death benefits under the applicable law.
• GSIS denied the claim on the basis that the illness was not deemed to be causally related to the performance of Patricio D. Armena’s duties or the conditions of his employment as municipal treasurer.
• A subsequent motion for reconsideration of the denial was also rejected, with the GSIS reaffirming that acute monocytic leukemia was not an occupational disease nor demonstrably linked to the work environment.

Appeal and Legal Argument

• Petitioner appealed to the Employees’ Compensation Commission, contending that the death should be presumed compensable under the former legal doctrine established under Section 44 of Act 3428 (the old Workmen’s Compensation Law).
• This argument was based on the assertion that an illness developing during the course of employment should be presumed to have arisen out of or been aggravated by that employment.
• The appeal also highlighted the so-called "long established legal and concrete doctrine" of presumptive compensability, which petitioner claimed should extend to claims under P.D. 626, as amended.

Examination of Medical and Causal Evidence

• The record noted that there was no evidence that Patricio D. Armena was exposed to conditions (such as X-rays, ionizing particles, radioactive substances, or other forms of radiant energy) that could have elevated his risk of developing leukemia in connection with his work.
• Expert medical observations clarified that monocytic leukemia is a generalized neoplastic disorder not easily attributable to occupational exposures, contrasting the exposure-related etiology seen in certain animal studies with the lack of similar evidence in humans.

Comparative Cases and Legal Precedents

• The decision referenced precedents such as Sulit vs. Employees’ Compensation Commission and Duran vs. Employees’ Compensation Commission.
• In Duran, death benefits were granted on the basis that the illness was linked indirectly to the prolonged treatment of work-related physical hardships experienced by a municipal judge.
• However, the record in the present case did not reveal analogous working conditions or any corroborative evidence establishing a similar chain of causation.

Issue:

Applicability of the Presumptive Compensability Doctrine

• Whether the doctrine of presumptive compensability, as derived from Section 44 of Act 3428, remains applicable under P.D. 626, as amended.
• Whether the petitioner is entitled to relief from proving a direct causal connection between her husband’s employment and his fatal illness by relying on a presumptive framework.

Causation between Employment and Death

• Whether the evidence on record sufficiently demonstrates that acute monocytic leukemia was caused by or aggravated by the nature of Patricio D. Armena’s employment as a municipal treasurer.
• Whether the working conditions of a municipal treasurer could plausibly increase the risk of developing such a disease.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)