G.R. No. 155076 - Laurel vs. Abrogar

Irnido L. Simacas was employed as a Fabrication Helper at Fieldstar Manufacturing Corporation from April 1995 until his retirement in February 2010.
During his employment, Irnido assisted the welder and machinist in cutting steel materials, an activity that involved strenuous physical labor in a cramped, crowded, and poorly ventilated work area.

Two years prior to his retirement, Irnido began experiencing back pain and incessant coughing, which he reported and for which he availed Fieldstar’s health care provider, Intellicare.
Despite being cleared for work by Intellicare, his symptoms progressively worsened, eventually impairing his ability to perform his job functions.

In February 2010, following a significant decline in his health, Irnido was retired from work. Later that month (February 20, 2010), he was hospitalized for a series of symptoms including back pains, cough, dysuria, night sweating, and fever.
During the hospitalization, he was diagnosed with multiple conditions: Benign Prostatic Hypertrophy (with a note “to consider” Prostatic Cancer), pneumonia, possible Pulmonary Tuberculosis, and he had been on medication for Tuberculosis while also diagnosed with Hepatitis A.
Subsequent hospitalization occurred due to severe chest and back pains and difficulty in breathing, eventually leading to his death on July 13, 2010, at the Philippine Orthopedic Center.

Irnido’s death certificate indicated that the immediate cause of death was Cardiopulmonary Arrest probably secondary to Metastatic Prostatic Adenocarcinoma.
His surviving spouse, Violeta A. Simacas, filed a claim for death benefits under Presidential Decree No. 626, as amended, which was initially denied by the Social Security System Sta. Maria Branch on the ground that his illness was a non-occupational disease.
The Social Security System’s Medical Operations Department further denied the claim based on the rationale that prostate cancer was not an occupational disease and had no causal connection with Irnido’s job duties.

The case was elevated to the Employees Compensation Commission (ECC) on May 21, 2012, which upheld the denial of the claim in its July 27, 2012 decision, emphasizing the lack of evidence linking Irnido’s work conditions with prostate cancer.
Violeta appealed the ECC decision before the Court of Appeals, which reversed the ECC ruling and ordered the Social Security System to pay the death benefits.
The Court of Appeals decision highlighted the social nature of Presidential Decree No. 626, promoting a liberal interpretation in favor of labor, and noted that requiring a direct causal relation was impracticable since the specific cause of prostate cancer is medically unknown.
Petitioner (Social Security System) subsequently filed a Petition for Review before the Supreme Court challenging the Court of Appeals’ decision and the ECC’s denial.

Petitioner argued that since prostate cancer is a non-occupational disease, the burden is on the claimant to prove that Irnido’s working conditions increased the risk of contracting the disease, contending that no substantial evidence was provided to establish a work connection.
Respondent maintained that the compensability standard under Presidential Decree No. 626 requires only a reasonable work connection rather than a direct causal relationship, and that the evidence, including circumstantial details of strenuous work conditions, is sufficient to establish that his working environment aggravated the risk of contracting prostate cancer.
Both parties submitted memoranda with the petitioner reiterating its position against the claim and the respondent adopting arguments favoring a liberal interpretation of the compensability requirements.

Whether or not the Supreme Court, in a petition for review, may reexamine factual findings made by the Court of Appeals.

Discussion centered on the principle that only questions of law should be raised in a petition for review.
Consideration was given to the exceptions wherein factual findings may be reexamined, such as instances of grave abuse of discretion or manifest error in fact-finding.

Whether or not respondent, Violeta A. Simacas, is entitled to death benefits under Presidential Decree No. 626, as amended.

The issue involves determining if there is sufficient evidence to prove that Irnido’s working conditions increased the risk of him contracting prostate cancer.
It also examines whether the absence of stringent evidentiary requirements (i.e., the need for only substantial evidence rather than direct causation) supports the grant of benefits.