Case Digest (G.R. No. 129892)
Facts:
Expedita Librea, widow of Eufronio Librea, claimed death compensation benefits from the Government Service Insurance System (GSIS) for the death of her husband on July 28, 1980 from terminal-stage cirrhosis of the liver. Eufronio, a public school classroom teacher who later became Division Physical Education Supervisor, had complained of illness in 1978, was confined on July 2, 1980 in Lipa City, and an attending physician certified that his illness may have been caused by the nature of his duties. The claim was denied by the GSIS and affirmed by the Employees’ Compensation Commission (ECC) on the ground that the ailment was not work-connected.On review, the Supreme Court set aside the ECC decision and ordered GSIS to pay P12,000.00 as death benefits, P1,000.00 as funeral expenses, and P1,200.00 as attorney’s fees. Both parties moved for reconsideration, with the petitioner challenging only the amounts of the awards and invoking PD 1368 and the GSIS insisting that the illness
Case Digest (G.R. No. 129892)
Facts:
- Employment and illness of the deceased
- Eufronio Librea started as a public school classroom teacher and rose to his last position as Division Physical Education Supervisor at the time of his death.
- Eufronio Librea died on July 28, 1980.
- In 1978, Eufronio Librea began to complain of a gradual loss of appetite, enlargement of the abdomen, and severe anemia.
- On July 2, 1980, Eufronio Librea was confined in a hospital in Lipa City.
- His ailment was diagnosed as cirrhosis of the liver in its terminal stage.
- The attending physician certified that the illness may have been caused by the nature of Eufronio Librea’s duties.
- Claim filed under the Employees’ Compensation scheme
- Expedita Librea, as widow, filed a claim for death compensation benefits with the Government Service Insurance System (GSIS).
- GSIS disapproved the claim on the ground that it was not work-connected.
- Motion for reconsideration before GSIS and denial by GSIS
- Expedita Librea filed a motion for reconsideration.
- She alleged that Eufronio Librea’s work was physically and mentally strenuous.
- She stated that he had to inspect regularly all districts in his Division.
- She alleged exposure to adverse weather conditions and extraordinary mental and physical fatigue due to distances between places.
- She alleged irregular meals and unhygienic eating habits due to lack of facilities.
- She asserted that these weakened his health and rendered him susceptible to a fatal disease.
- GSIS denied the motion for reconsideration and stressed that the cited conditions of work were not causally connected to the illness.
- Review before the Employees’ Compensation Commission (ECC)
- Expedita Librea sought review of GSIS’s denial before the Employees’ Compensation Commission (ECC).
- The ECC affirmed the GSIS decision.
- Petition for review and initial Supreme Court disposition
- Expedita Librea brought the case to the Supreme Court via a petition for review on certiorari.
- The Supreme Court set aside the ECC decision.
- The Supreme Court ordered GSIS to pay:
- P 12,000.00 as death benefits;
- P1,000.00 as funeral expenses; and
- P1,200.00 as attorney’s fees.
- The Supreme Court’s grounds in the earlier decision included:
- The duties and functions of Eufronio Librea as teacher and later as supervisor for 32 years may have rendered him susceptible to contracting the fatal illness.
- The physician’s opinion shared that possibility.
- The Supreme Court considered his duties as fraught with mental and physical strain, including hunger or insufficient food, leading to nutritional deficiency that may be a primary factor in the development of the disease.
- The Supreme Court treated the physician’s report as the best evidence of work-connection because the attending physician was in the best position to judge possible causal relation between the illness and the work performed and would not normally make a false certification.
- The Supreme Court stated that the findings of doctors of GSIS and ECC were not binding on the Supreme Court.
- The Supreme Court considered Eufronio Librea’s 32 years of devoted service.
- Motions for reconsideration after the November 14, 1991 Supreme Court decision
- Both parties moved for reconsideration of the Supreme Court’s decision dated November 14, 1991.
- The Supreme Court’s earlier decision set aside ECC’s decision and ordered payment of:
- P12,000.00 as death benefits; and
- P1,200.00 as attorney’s fees.
- Issues raised in Expedita Librea’s motion for reconsideration
- Expedita Librea questioned the amount of the award.
- She invoked PD 1368, which amended Art. 194 of the Labor Code (effective May 1, 1978).
- She argued that under PD 1368, monthly income benefits for permanent total disabilities and deaths like the present case are lifetime for as long as the primary beneficiaries remain qualified.
- She argued that the benefits would start in July 1980.
- She contended that the maximum award of Twelve Thousand Pesos was applicable only to contingencies occurring before May 1, 1978, citing Rule XIII, Sec. 4, Amended Rules on Employees’ Compensation.
- Issues raised in GSIS’s motion for reconsideration
- GSIS asserted that it committed no abuse of discretion in dismissing the claim.
- GSIS relied on Art. 167 (1) of the Labor Code, clarified by Rule III, Sec. 1 (b) and (c) of the Amended Rules and Regulations on Employees’ Compensation.
- GSIS stated that for an illness to be compensable, it must be among the ailments cited in Annex “A” of the Amended Rules or, alternatively, the claimant must prove that the risk of contracting such illness was increased by the conditions of employment of the deceased employee.
- GSIS argued that the alleged strenuous physical and mental activities and alleged irregular meals and unhygienic eating habits did not increase the risk of contracting the disease.
- GSIS relied on Garol v. ECC, 168 SCRA 108.
- GSIS argued that the presumption of compensability had been discarded under the Labor Code.
- GSIS maintained that the employee now had the burden of proving the relation of causation between conditions of employment and the illness sought to be compensated.
- GSIS relied on Sulit v. ECC, 98 SCRA 483 (1980).
- Reconsidered Supreme Court disposition
- The Court found for GSIS.
- It held that the old ruling on presumption of compensability, controversion, adversarial procedure, and levels of payment no longer applied.
- It recognized that the Labor Code had drastically revised workmen’s compensation into a social insurance fund scheme.
- It stated that under the old system, the employer shouldered compensation and op...(Subscriber-Only)
Issues:
- Whether the claim for death compensation for cirrhosis of the liver was compensable as a work-connected illness
- Whether cirrhosis of the liver may be treated as work-connected based on the attending physician’s certification and the alleged nature of the deceased’s duties.
- Whether the conditions alleged by petitioner—mental and physical strain, exposure to adverse weather, distances causing fatigue, irregular meals, and unhygienic eating habits—were causally connected to, or increased the risk of contracting, cirrhosis of the liver.
- Whether the presumption of compensability still applied under the Labor Code and Amended Rules on Employees’ Compensation
- Whether the earlier Supreme Court approach relying on presumption-like reasoning and the physician’s report as best evidence remained applicable after the enactment of the Labor Code and its rules.
- Whether, under the present scheme, the claimant bore the burden of proving the relation of causation and increased risk by employment conditions.
- Whether the Supreme Court correctly ordered the amount of ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)