Title
Duran vs. Employees' Compensation Commission
Case
G.R. No. 52363
Decision Date
Mar 30, 1982
Widow seeks death benefits for judge’s leukemia, claiming work-related illnesses and treatment complications; SC rules in her favor, citing compensability presumption.
death benefits
medical expenses
funeral expenses
A

Case Summary (G.R. No. 52363)

Factual Background

The records showed that Restituto Duran entered government service on October 15, 1941 with the Department of Finance. He joined the Judiciary on May 31, 1952 as justice of the peace for the municipalities of Basay, Sta. Rita, and Marabut in Samar. He later became the municipal judge of Sta. Rita, Samar on April 1, 1964, a station described as having thirty-one barrios and lacking adequate transportation facilities such that he traveled mostly by foot or banca.

Petitioner’s husband suffered from prolonged illnesses prior to his death. From March 1972 until his death on April 28, 1977, he was treated and hospitalized for castralgia, angina pectoris, gouty arthritis, myofascitis, coronary insufficiency, hypocalcenia with cramps, and ultimately acute monocytic leukemia. His medical history, as traced in the record, included confinement for angina pectoris and related conditions in March 14–18, 1972, hospitalization in April 11–14, 1973 for arthritis and related ailments, confinement and an operation (tophectomy) in October 8–18, 1973 for gouty arthritis with tophaceous deposits, and further hospitalizations for gouty arthritis in November 10–17, 1976 and March 1–8, 1977, culminating in hospitalization for gouty arthritis and monocytic leukemia shortly before death. The cause of death was recorded as acute monocytic leukemia.

Claims, Denials, and Appeal

Petitioner filed her claim with the GSIS on March 14, 1978 for income (death) benefits under Presidential Decree No. 626, as amended. The GSIS denied the claim on March 28, 1978. Petitioner then requested reconsideration on June 23, 1978, and the GSIS denied that request through a letter dated June 30, 1978. She appealed to the Employees’ Compensation Commission on January 19, 1979. On October 31, 1979, the Commission affirmed the GSIS denial and upheld the non-compensability of the death under the compensation law.

Findings of the Employees’ Compensation Commission and GSIS

The Commission ruled that the sickness and resulting death could be compensable only if the sickness was the result of an occupational disease listed under Annex “A” of the applicable rules and the conditions therein were satisfied. Alternatively, it required proof that the risk of contracting the sickness was increased by the claimant’s working conditions. It held that leukemia was not an occupational disease considering the decedent’s work. It further found it “farfetched” to attribute the ailment to the nature and conditions of the work, reasoning that it was medically accepted to be caused by external factors unrelated to employment.

The ruling on non-compensability relied on the report of the ECC medical officer. That report stated that the cause of death was acute monocytic leukemia, and that the records showed no indications that the deceased, as a former municipal judge, had been exposed to factors listed as possible causes of the disease in the course of his work. It noted an allegation that the disease might have resulted from prolonged treatment for gouty arthritis. Even granting that possibility, it concluded that the disease could not be considered compensable because the disease being treated was not occupational or work-connected.

Petitioner’s Theory of Compensability

Petitioner asserted that as a municipal judge, Restituto Duran conducted hearings, performed ocular inspections, and settled disputes through amicable settlement or mediation outside the courtroom. She also claimed that he accepted speaking engagements at conferences and seminars. Petitioner emphasized the arduous and exposed nature of a judge’s field work in areas without adequate transportation. She narrated that it was not unusual for him to wade through brooks and streams to implement the policy of bringing courts closer to the people. She further averred that the work schedule, which continued for over twenty years, contributed to his illnesses, and that he began to show symptoms of heart disease as he developed arthritis. Petitioner linked a collapse while holding session to his later hospitalization, where he was reportedly found to be suffering from coronary insufficiency aggravated by arthritis.

Petitioner’s position, as ultimately sustained by the Court, rested on the sufficiency of the evidence of an employment-related chain of events leading to the fatal condition, and on the controlling presumptions in compensation cases when exact causation could not be definitely determined.

Respondents’ Position

The Solicitor General, for respondents, argued that although Restituto Duran contracted illness during employment, his death for which compensation was sought was not due to coronary insufficiency but to leukemia. Respondents contended that this distinction ruled out recovery under the Workmen’s Compensation Act, and that relief likewise could not be obtained under the Labor Code, particularly invoking Article 166, which, as they described it, requires work-connected disability or death as a condition for income benefits and related medical benefits.

The Court’s Reasoning on Presumptions, Causation, and Medical Uncertainty

The Court accepted petitioner’s position and set aside the Commission’s decision. It characterized the Commission’s approach as a stereotyped handling of compensation claims and as inconsistent with the Court’s established pronouncements. The Court stressed the circumstances of Restituto Duran’s judicial work. It found that Sta. Rita had many barrios and that there was no adequate transportation, so that the deceased traveled mostly on foot or by banca and was exposed to sun, rain, water, and rough roads. It noted that his duties included regular hearings and ocular inspections and extended to settling disputes outside the courtroom and speaking in conferences and seminars. The Court treated those facts as indicating prolonged and unhealthy exposure in the performance of judicial functions, with the illnesses developing only after about twenty years of service.

The Court also invoked the doctrine that compensability is not defeated merely because extraneous factors may have caused or accelerated the illness. Citing Lao vs. Employees’ Compensation Commission, et al., it reiterated that it was not required that employment be the sole factor in the growth, development, or acceleration of the illness for entitlement to arise. It ruled that the Commission’s conclusion that leukemia was not occupational because the work did not medically expose the deceased to listed causes was not fully responsive to the medical and evidentiary context, especially where leukemia could be related to the prolonged treatment of the decedent’s other ailments.

The Court further held that the Commission failed to appreciate established medical findings in the record that leukemia may be a complication or after-effect of prolonged treatment. It highlighted cited medical references indicating that while the precise cause of leukemia might be unknown, genetic and environmental factors were important, and that acute leukemia could be linked to irradiation and chemical exposures. It also cited medical authorities stating that chemical agents and certain drugs, including chloramphenicol and phenybutazone, could be leukemogenic or associated with bone marrow depression, and that certain risks may be increased by occupational exposure to benzol. The Court then connected these references to the factual medical treatment history of the deceased, stating that from March 1972 to April 28, 1977, he received continuous analgesics and antibiotics as part of treatment for his coronary insufficiency and gouty arthritis. It reasoned that because chloramphenicol was the technical name for an antibiotic and phenybutazone for anti-rheumatic drugs, and because the record showed prolonged treatment, there was an evidentiary opening to conclude that the fatal leukemia could have been linked to the prolonged medication.

The Court treated the medical reports and the Commission’s own statements as having created a factual basis for this causal inference. It noted that the ECC medical officer’s report, quoted by the Commission, acknowledged the allegation that the disease could have resulted from prolonged gouty arthritis treatment, but then rejected compensability on the ground that the disease for which treatment was given was not occupational or work-connected. The Court found this distinction untenable after the work-connection or causal relationship underpinning the treatment had been sufficiently established.

To resolve uncertainty about the precise cause, the Court invoked compensation doctrines on medical presumption and the shifting of burden where causation was not definitely determinable. It cited Enriquez vs. WCC, et al. for the principle that where the primary injury arises in the course of employment, every natural consequence that flows from it also arises out of employment unless attributable to an independent intervening cause due to claimant’s negligence or misconduct. It likewise cited authorities that where a compensable injury is aggravated by medical or surgical treatment without fault of the employee, there is a causal connection between the original injury and the resulting disability or death for compensability, even if the medical treatment is skillful and even if selected by the employee.

The Court also reiterated the approach applied in LaO vs. ECC that where the cause of

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