Title
Cristobal vs. Employees' Compensation Commission
Case
G.R. No. L-49280
Decision Date
Feb 26, 1981
A widow successfully claims death benefits and reimbursement for medical and funeral expenses after her husband's death from rectal cancer, with the court ruling that the disease was caused or increased by his working conditions, applying the theory of increased risk and emphasizing the liberal and compassionate spirit of the law.
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Case Digest (G.R. No. L-49280)

Facts:

  • Luz G. Cristobal, widow of Fortunato Cristobal, sought death benefits and reimbursement for medical and funeral expenses after her husband's death from rectal cancer.
  • Fortunato Cristobal was a Supervising Information Officer at the Bureau of Printing under the National Science Development Board (NSDB).
  • He began his government service in 1964, initially free from any disease.
  • Over time, he was exposed to various chemicals and intense heat in his workplace, which was described as unhygienic and polluted.
  • Despite his illness, Fortunato continued working until he was diagnosed with rectal cancer and passed away on May 27, 1977.
  • Luz Cristobal filed a claim for benefits, which was initially granted by the court on April 30, 1980.
  • The court ordered the Government Service Insurance System (GSIS) to pay P12,000.00 as death benefits, reimburse medical, surgical, and hospital expenses, pay P700.00 for funeral expenses, and cover attorney's fees equivalent to 10% of the death benefits.
  • GSIS and the Employees' Compensation Commission (ECC) filed motions for reconsideration, challenging the compensability of the illness, the amount of benefits awarded, and the propriety of attorney's fees.

Issue:

  • (Unlock)

Ruling:

  • The court ruled that rectal cancer is compensable under the theory of increased risk.
  • The court upheld the amounts awarded as death benefits and funeral expenses, with a modification to increase the funeral expenses to P1,000.00....(Unlock)

Ratio:

  • The court's decision was based on the theory of increased risk under Section 1(b) Rule III of PD 626, which requires proof that the risk of contracting the disease was increased by the working conditions.
  • Substantial evidence supported the work-connection of Fortunato Cristobal's illness, considering his exposure to unhygienic conditions, chemicals, and intense heat at the Bureau of Printing.
  • The court emphasized the liberal and compassionate spirit of the law, as embodied in Article 4 of the new Labor Code, which mandates resolving all doubts in favor of labor.
  • The court rejected the respondents' insi...continue reading

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