G.R. No. L-47405 - Santiago vs. Employees' Compensation Commission

Clarita E. Santiago was employed as a classroom teacher with the Bureau of Elementary Education since 1956.
She was assigned to Guerilla Elementary School, Bo. Concepcion, San Pablo City.
Her employment involved not only routine classroom activities but also supervisory tasks and participation in various extra-curricular, out-campus programs such as the green revolution and youth civic action programs (YCAP).
She also actively participated in scouting, teachers’ seminars, community work, and civic activities including organizing barangay youth and serving in election committees, which expanded her job responsibilities beyond the conventional classroom setting.

The petitioner first experienced symptoms, including hypogastric and lumbar pains, nausea, vomiting, scanty urination, on-and-off fever, and general malaise, beginning on March 25, 1975.
On May 24, 1976, she was admitted to Good Samaritan Hospital in San Pablo City where these symptoms were further evaluated.
Her clinical diagnosis at the time was “Kidney Stones, Bilateral, Pyelonephritis, Secondary,” and she was discharged without marked improvement.

In response to her deteriorating health, the petitioner applied for disability retirement under Republic Act 1616.
On July 26, 1976, she filed a claim for income benefits with the Government Service Insurance System (GSIS) under Presidential Decree No. 626, as amended, asserting that her ailment was caused by the nature of her employment.
On August 5, 1976, GSIS denied her claim on the ground that her condition was neither an occupational disease nor directly caused by her employment.
The petitioner sought reconsideration on September 7, 1976, which was dismissed by GSIS in a letter dated September 13, 1976.
The case was further elevated to the Employees’ Compensation Commission (ECC), which affirmed the decision of the GSIS in denying her claim.

The record reveals that despite the initial classification of her condition as non-occupational, there were indications that her work-related activities contributed to her health issues.
Notably, her classroom was described as having no ceiling with a galvanized iron roof, exposing her to excessive heat.
The petitioner’s out-campus duties and physical activities possibly resulted in conditions (such as dehydration and urinary irregularity) conducive to the formation of kidney stones.
Medical evidence and principles highlighted that kidney stones (Staghorn Calculi) are linked to chronic dehydration, urinary obstruction, and infection, which in her case was aggravated by her working conditions.

Whether the petitioner’s ailment—characterized primarily by Staghorn Calculi and secondary pyelonephritis—is compensable as an occupational disease under Presidential Decree No. 626, as amended.
Whether the evidence on record sufficiently establishes a causal link between the petitioner’s working conditions (including exposure to heat from the unceilinged galvanized iron roof and strenuous duties) and the development or aggravation of her illness.
Whether the distinctive nature of her employment and extracurricular duties contributed significantly to the onset of her kidney afflictions, thereby warranting compensation despite the primary disease not being explicitly listed as compensable under Annex “A”.
Whether the petitioner’s unsubstantiated claim regarding heat exposure in the classroom can be corroborated by tangible evidence and supported by expert medical diagnosis.