Case Digest (G.R. No. L-66174)
Facts:
Angeles Bravo filed a petition for review on certiorari challenging the decision of the Employees' Compensation Commission (ECC) which affirmed the denial of her late husband Evelio Bravo's claim for disability benefits. Evelio was employed as a litho-photo engraving supervisor at the Bureau of Coast and Geodetic Survey, where he began his career on May 13, 1959, and rose through various positions until retirement. During his tenure, Evelio was involved in tasks that required working with chemicals in lithographic processes. In November 1979, he began experiencing irregular bowel movements, constipation, and abdominal pain, which culminated in a diagnosis of adenocarcinoma of the sigmoid colon (stage C) and chronic peri-appendicitis on April 20, 1980. Following multiple surgeries and a hospitalization bill of P8,650.05, he retired on June 1, 1980, at the age of 48, receiving approximately P37,002.31 from the Government Service Insurance System (GSIS) as part of his retirement beCase Digest (G.R. No. L-66174)
Facts:
Evelio Bravo was employed with the Bureau of Coast and Geodetic Survey, where through a series of promotions he eventually became a litho-photo engraving supervisor. In that role, he was exposed to various chemicals involved in drafting, plate printing, and the processing of light-sensitive lithographic solutions. In November 1979, Bravo began experiencing digestive complaints, and by April 1980 he was admitted to a hospital where he was diagnosed with adenocarcinoma of the sigmoid colon (at Duke’s stage C) and chronic peri-appendicitis. After undergoing multiple operations and incurring significant medical expenses, Bravo was discharged but did not resume work. Ultimately, he retired under Republic Act No. 1616 at age forty-eight and received a retirement gratuity from the GSIS. On August 11, 1980, Bravo filed a claim for disability benefits under Presidential Decree No. 626, alleging that his illness was work-related due to his exposure to chemicals. The claim was denied by the GSIS on the ground that neither cancer of the colon nor peri-appendicitis were recognized as occupational diseases in his position. Bravo’s widow, Angeles, later pursued a petition for certiorari, contending that there was a reasonable work-connection and an increased risk arising from his exposure and stressful working conditions.Issues:
- Whether adenocarcinoma of the sigmoid colon and chronic peri-appendicitis, which resulted in Bravo’s death, can be considered compensable occupational diseases under the Labor Code.
- Whether the evidence showing exposure to chemicals in his employment, and the “probability” that such exposure increased the risk of developing cancer, is sufficient to allow a claim based on the increased risk doctrine.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)