G.R. No. 57623 - Juala vs. Employees' Compensation Commission

Candelaria Juala, the deceased, began her government service on January 19, 1954, with the Highway District Engineers Office in San Jose, Antique.
Over the span of her career, she advanced through several positions—from computer aide, clerical aide, clerk I, clerk II, to senior clerk (the position she held from 1972 until her death in 1975).
Her responsibilities as senior clerk included managing the Personnel and Training Unit, which involved:

The onset of health issues was noted in July 1975 when the deceased experienced pain in the left lumbar region and buttocks.
She received prompt treatment from her family physician, Dr. Guillermo Javier, and was declared recovered by August 31, 1975; however, she resumed work on September 1, 1975.
Subsequent health deterioration led to:

Hospitalization on September 19, 1975 at Antique Doctor’s Hospital for severe anemia, with discharge on September 29, 1975.
Re-hospitalization three days later at Iloilo Doctor’s Hospital where she underwent a transverse colostomy.

The deceased eventually succumbed on October 13, 1975 due to a ruptured tumor secondary to hepatic flexure, and she was also noted to have nephrolithiasis.

Following the death of Candelaria Juala, her surviving spouse, Felipe Juala, filed a claim for death benefits under P.D. No. 626 (as amended).
The claim was initially denied by the Government Service Insurance System (GSIS) on the basis that there was no causal relationship between her employment and her fatal illnesses, as supported by medical findings.
The denial was subsequently affirmed by the Employees’ Compensation Commission (ECC) on November 7, 1980, with the contention that the nature of the deceased’s clerical duties did not predispose her to the diseases in question.

The deceased was physically and mentally healthy at the commencement of her employment in 1954, and her career progression evidenced a sustained work ethic under challenging conditions.
The extensive responsibilities, prolonged work hours, and high degrees of stress in her job contributed to neglect of personal comfort (e.g., delaying meals or restroom breaks), which could have predisposed her to developing nephrolithiasis and ultimately contributed to the onset of a tumor.

The clerical nature of the work did not involve continuous, strenuous physical exertion sufficient to cause the diseases.
The etiological factors of nephrolithiasis and tumor of the hepatic flexure are not work-related, being linked instead to non-occupational factors and established medical conditions.

Tumor of the hepatic flexure is a form of colon cancer often associated with adenomatous polyps, chronic inflammatory conditions (e.g., ulcerative colitis), and familial predispositions—even though its precise cause remains uncertain.
Nephrolithiasis is caused by the precipitation of chemical salts in the kidney, influenced by factors such as urine concentration, encrustation, urinary obstruction, and hyperparathyroidism, which are generally not related to clerical work.

The inherent uncertainty in pinpointing the exact cause of cancers, thereby relieving petitioners from the burden of proving direct causation.
Precedents (e.g., Acosta vs. ECC and Dator v. ECC) that support reliance on showing a reasonable work-connection or increased risk rather than a strict causal link.

Whether the death of Candelaria Juala from nephrolithiasis and a ruptured tumor secondary to hepatic flexure is compensable under P.D. No. 626, as amended.
Whether the evidence on record is sufficient to establish a reasonable work-connection between her employment conditions and the development of her fatal ailments.
Whether the denial of benefits by the GSIS and affirmation by the ECC, based on the lack of a direct causal relationship, improperly disregarded the possibility of increased risk due to occupational stress and overwork.