G.R. No. 47277 - El Pueblo de Filipinas vs. Estranero

Sigfredo A. Dabatian was employed as a Garbage Truck Driver in the General Services Department of the City Government of Cagayan de Oro City.
He was primarily assigned to the night shift, with his duty schedule from 10:00 PM to 6:00 AM.
His work conditions required him to be alert during hours typically associated with sleep, which he countered by heavy coffee drinking.

Witnesses observed that prior to his collapse, the deceased demonstrated signs of physical deterioration – becoming progressively paler and weaker.
He eventually collapsed while on duty and was brought home by his companions.
Despite hospitalization following the incident, his condition worsened and he died two weeks later on July 3, 1976.
The deceased’s main ailment was identified as peptic ulcer, a disease characterized by a sharply circumscribed loss of tissue due to the digestive action of acid gastric juice.

A claim for income benefits under the Employee’s Compensation Program was filed by his widow, Hilaria Dabatian.
The Government Service Insurance System (GSIS) denied the claim on the ground that peptic ulcer is not definitively accepted as an occupational disease under the applicable compensation law.
The Employees’ Compensation Commission (ECC) affirmed GSIS’s denial after evaluating medical evidence and opinions from generally accepted medical authorities.
The ECC determined that the disease was primarily a result of non-work-related factors, particularly the deceased’s heavy coffee drinking, rather than the conditions of his employment.
A petition for review was later filed by Hilaria Dabatian, even though she failed to file the necessary memorandum in due time.

Medical authorities, including references from Harrison’s Principles of Internal Medicine, were cited to explain the pathogenesis and aggravating factors of peptic ulcer.
While factors such as alcohol consumption, cigarette smoking, and certain drugs can contribute to the development or delayed healing of peptic ulcer, the ECC emphasized that aggravation of an illness does not constitute a ground for compensation under the current law.
The ECC underscored that there was no evidence showing that the risk of acquiring peptic ulcer was materially increased by the deceased’s employment conditions.

Whether the death of Sigfredo A. Dabatian is compensable under the conditions set by the present compensation law.

The central issue was whether the presumption of compensability and the principle of aggravation, which were applicable under the old compensation law, could still be used as a basis for awarding benefits.
The case raised the question of whether petitioner could prove that the deceased’s work conditions materially increased the risk of contracting peptic ulcer.

The evidence indicated that the deceased died after the effectivity of the New Labor Code (P.D. 442 as amended), which abolished the presumption of compensability.
Whether the absence of any competent evidence showing the contraction of the disease prior to January 1, 1975, would preclude compensability under the old compensation law.