Case Digest (G.R. No. L-48602)
Facts:
Fe N. Sulit v. Employees' Compensation Commission and Government Service Insurance System, G.R. No. L-48602, June 30, 1980, Supreme Court Second Division, Aquino, J., writing for the Court.The petitioner is Fe N. Sulit, widow of Gregorio S. Sulit, who was employed as a mechanic at the Cavite Naval Shipyard, Naval Shore Establishment, from May 26, 1966 until his death on December 17, 1975. Gregorio Sulit's duties involved inspection, repair and overhaul of ship propulsion and auxiliary engines and related mechanical equipment, including work requiring disassembly, reassembly, installation and alignment of heavy mechanical components; petitioner alleged frequent prolonged work in a prone position under vehicles and equipment.
Gregorio Sulit was hospitalized at the Philippine General Hospital from December 11 to December 17, 1975, and died of acute pyelonephritis and bronchopneumonia. Pyelonephritis is described in the record as an acute pyogenic kidney infection that may be predisposed by urinary obstruction (strictures, calculi, prostatic hypertrophy) or seeded from other infectious foci; bronchopneumonia is described as a complication of a debilitating disease.
Petitioner filed a claim for employee's compensation under Presidential Decree No. 626 (the Labor Code provisions on employees' compensation), asserting that the decedent’s postural, time-consuming work produced kinking of his ureters, caused urinary stasis, infection and stone formation, and thus that his fatal pyelonephritis (and resulting bronchopneumonia) were work-connected. The Government Service Insurance System (GSIS) rejected the claim on initial processing, finding the diseases not occupational and that the working conditions did not increase the risk of contracting them. On appeal the Employees' Compensation Commission (the Commission) affirmed the denial, noting that aggravation of disease by work was no longer a legal basis for compensation under the Labor Code. Petitioner then appealed to the Supreme Court.
Petitioner additionally asserted denial of due process because she was not afforded an opportunity to be heard. The GSIS maintained that the statutory administrative claims process does not require a formal adversary hearing on initial filing, that claimants may submit supporting papers and that...(Pro-only)
Issues:
- Was petitioner denied due process in the GSIS/Commission proceedings?
- Are acute pyelonephritis and bronchopneumonia compensable as occupational diseases under Presidential Decree No. 626 (employees' compensation provisions of the Labor Code) on t...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)