Title
Belarmino vs. Employees' Compensation Commission
Case
G.R. No. 90204
Decision Date
May 11, 1990
A public school teacher’s fall during work led to premature delivery, septicemia, and death; SC ruled her death compensable under Employees Compensation Law.
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Case Digest (G.R. No. 90204)

Facts:

  1. Background of the Case:

    • The case involves a claim for death benefits filed by Manuel Belarmino, the husband of Oania Belarmino, a public school teacher who died due to septicemia post partum.
    • Oania Belarmino had been a classroom teacher at Buracan Elementary School in Dimasalang, Masbate, for 11 years.
  2. The Accident:

    • On January 14, 1982, while performing her duties as a classroom teacher, Oania, who was in her 8th month of pregnancy, slipped and fell on the classroom floor.
    • She experienced abdominal pain and stomach cramps shortly after the fall but continued working despite advice to take a leave of absence.
  3. Premature Delivery and Complications:

    • On January 25, 1982, Oania went into premature labor and delivered a baby girl at home.
    • She continued to suffer from abdominal pain, high fever, and headache after delivery.
    • She was hospitalized on February 11, 1982, and diagnosed with septicemia post partum due to infected vaginal lacerations.
    • She was discharged on February 16, 1982, but died three days later on February 19, 1982.
  4. Claim for Benefits:

    • Manuel Belarmino filed a claim for death benefits on April 21, 1983.
    • The Government Service Insurance System (GSIS) denied the claim, stating that septicemia post partum was not work-connected and that the accident did not cause her death.
    • The Employees Compensation Commission (ECC) upheld the denial, ruling that the septicemia resulted from factors not inherent in her employment.

Issue:

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Ruling:

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Ratio:

  1. Proximate Cause Doctrine:

    • The fall in the classroom was the proximate cause of Oania’s death. It set in motion a chain of events (premature delivery, septicemia, and death) that were directly linked to her employment.
    • The Court cited the principle that all medical consequences flowing from a primary injury arising in the course of employment are compensable.
  2. Compensability Under the Employees Compensation Law:

    • Although septicemia post partum is not listed as an occupational disease, the conditions of Oania’s employment contributed to its development.
    • The fall occurred at her workplace while she was performing her duties, fulfilling the requirements for compensability under Rule III, Section 1 of the Amended Rules on Employees Compensation.
  3. Social Justice and Compassion:

    • The Court emphasized the government’s responsibility to provide adequate social services and improve the quality of life for public servants, particularly underpaid public school teachers.
    • The denial of the claim ignored the economic realities faced by public school teachers and their inability to afford proper medical care.
  4. Grave Abuse of Discretion:

    • The public respondents’ failure to consider the proximate cause of Oania’s death and the socio-economic context of her situation constituted grave abuse of discretion.


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