G.R. No. 94010 - Evardone vs. Commission on Elections

Diosdado Sagliba, the deceased, was employed with the government starting July 17, 1969, as a statistician at the Bureau of Agricultural Economics in Tacloban City.
He was promoted to senior statistician on July 1, 1973, and held that position until his death in 1981.

In early 1981, Diosdado Sagliba experienced symptoms of general weakness, anorexia, and easy fatigability.
He also had an episode of melena, for which he received Irgamet 200 mg. tablets for 7 days, and was treated as an outpatient for hematemesis at Bethany Hospital, where a bleeding peptic ulcer was detected.
His condition deteriorated, leading him to be admitted to Capitol Medical Center in Quezon City on April 27, 1981, where he presented with vomiting of fresh and clotted blood, dizziness, and slight abdominal pain.
An exploratory laparotomy and liver biopsy were performed by Dr. Agapito Tuazon, Jr., leading to the diagnosis of “carcinoma, liver; bleeding varices; malnutrition; sepsis; hepatic coma.”
Diosdado Sagliba died on May 7, 1981, at the age of 37, with the cause of death being hepatic failure due to sepsis and hepatoma.

After the death of her husband, his widow, petitioner Nemia Sagliba, filed a claim for death compensation benefits under P.D. 626, as amended, with the Government Service Insurance System (GSIS).
GSIS denied the claim on the ground that the fatal ailment, hepatoma, was not work-connected.
The petitioner further appealed by writing a letter to the Office of the President, which referred the claim to the Employees’ Compensation Commission (ECC).
The ECC rendered a decision affirming the GSIS ruling, thereby dismissing the claim for compensation.

As senior statistician, the deceased was assigned to Region 8 as the Regional Coordinator of Samar-Leyte and the Biliran sub-province, involving significant travel to remote areas.
His job required early mornings, long working hours, use of a government vehicle, and interaction with various environments that exposed him to harsh weather, unhygienic conditions, and possible parasitic infections.
Routine job-related fatigue and the neglect of regular meals contributed to his malnourished state by the time of hospitalization.

Respondents based their denial on medical evaluations, stating that hepatoma is a primary malignant tumor of the liver with predisposing factors such as parasitic infestation, dietary deficiency, chemical irritants, and chronic alcoholism.
The Medical Division’s findings highlighted that hepatoma, in most series, accounts for 80 to 90% of liver cell carcinomas, with rapid disease progression and high fatality within six months.
Both petitioner and respondent evidence acknowledged that the precise etiology of hepatoma remains unknown and may involve multiple factors, including those that could be associated with the working conditions of the deceased.

Whether hepatoma, the fatal ailment that led to the death of Diosdado Sagliba, is work-connected and thus compensable under P.D. 626, as amended.

Petitioner contends that the deceased’s employment—as evidenced by his duties, travel, exposure to unhygienic conditions, and resulting excessive fatigue—directly contributed to the development or aggravation of his fatal disease, thereby establishing a work-connection.
Respondents argue that the principles of aggravation and the presumption of compensability under the New Labor Code no longer apply, insisting that there was no concrete proof that the work environment increased the risk of contracting hepatoma.