Title
Librea vs. Employees' Compensation Commission
Case
G.R. No. 58879
Decision Date
Mar 6, 1992
A public school teacher’s widow sought death benefits, claiming his cirrhosis was work-related. The Supreme Court denied the claim, ruling insufficient evidence linked his illness to his job duties.
widow
compensation benefits
cirrhosis of the liver
A

Case Summary (G.R. No. 58879)

Factual Background

The record showed that in 1978 Eufronio Librea began to complain of gradual loss of appetite, enlargement of the abdomen, and severe anemia. On July 2, 1980, he was confined in a hospital in Lipa City, where his condition was diagnosed as cirrhosis of the liver in its terminal stage. He died of the same ailment on July 28, 1980. The attending physician certified that the illness may have been caused by the nature of his duties.

Petitioner thereafter filed a claim for death compensation benefits with the GSIS. The GSIS disapproved the claim on the ground that the illness was not work-connected. Petitioner moved for reconsideration, asserting that her husband’s work as a teacher and later as supervisor was physically and mentally strenuous because he had to inspect districts within his division regularly. She also claimed exposure to adverse weather conditions and extraordinary mental and physical fatigue attributable to the distances between places. She further alleged irregular meals and unhygienic eating habits due to lack of facilities, contending that these circumstances weakened his health and made him susceptible to a fatal disease.

The GSIS denied the motion and maintained that the cited conditions were not causally connected to the illness. Petitioner then sought review before the ECC, which affirmed the GSIS decision.

Proceedings Before the Supreme Court

Petitioner brought the matter to the Supreme Court through a petition for review on certiorari. The Supreme Court initially set aside the ECC’s decision and ordered the GSIS to pay P12,000.00 as death benefits, P1,000.00 as funeral expenses, and P1,200.00 as attorney’s fees. The Court’s basis at that stage was, first, that the deceased’s duties over 32 years as teacher and supervisor may have rendered him susceptible to the fatal illness, with the attending physician sharing the view that his duties involved mental and physical strain and nutritional deficiency. Second, it treated the physician’s report as the best evidence of work-connection because the attending physician was in the best position to judge causal relation, and it reiterated that the GSIS and ECC findings were not binding on the Supreme Court. Third, it considered the deceased’s 32 years of devoted service.

Subsequently, both parties moved for reconsideration of the Supreme Court decision promulgated on November 14, 1991. Petitioner and GSIS both challenged the legal correctness of the outcome.

The Motions for Reconsideration: Parties’ Contentions

Petitioner specifically questioned the amount of the award. She relied on PD 1368, which amended Art. 194 of the Labor Code (effective May 1, 1978) and provided that monthly income benefits for permanent total disabilities and deaths similar to the present case were to be paid lifetime, as long as the primary beneficiaries remained qualified. She argued that those benefits would begin in July 1980. Petitioner further contended that the maximum award of Twelve Thousand Pesos applied only to contingencies occurring before May 1, 1978 (citing Rule XIII, Sec. 4, Amended Rules on Employees’ Compensation).

GSIS, in its motion, argued that it had not abused discretion when it dismissed the claim because cirrhosis of the liver was not among the ailments compensable under the applicable scheme. It anchored its position on Art. 167 (1) of the Labor Code, clarified by Rule III, Sec. 1 (b) and (c) of the Amended Rules and Regulations on Employees’ Compensation, asserting that for an illness to be compensable, it must be listed in Annex “A” of the amended rules, or the claimant must prove that the risk of contracting the illness was increased by the deceased employee’s conditions of employment—an increase which, according to GSIS, had not been shown.

GSIS also claimed there was no substantial evidence that the deceased’s allegedly strenuous activities, his exposure as a division head, and his irregular meals and unhygienic eating habits increased the risk of contracting the disease, invoking Garol v. ECC. Finally, GSIS contended that under the current statutory and rules framework the presumption of compensability had been discarded. It asserted that the employee or claimant now bore the burden of proving the relation of causation between conditions of employment and the illness, invoking Sulit v. ECC.

Legal Basis and Reasoning on Reconsideration

On reconsideration, the Court ruled for GSIS and reconsidered its earlier decision. Central to the resolution was the Court’s clarification that the former system of employees’ compensation and its presumptions no longer governed after the drastic revision with the enactment of the Labor Code. The Court explained that under the earlier employer-borne scheme, fraud or unmeritorious claims were addressed through an adversarial process between employer and employee, and thus a presumption of compensability evolved: where an illness occurred during employment, the disease was presumed compensable unless the employer proved otherwise.

Under the present scheme, however, the Court held that no such presumption existed. If the sickness was not one of the ailments listed in the Amended Rules as compensable without need of proof, then the claimant had to establish that the employment caused the illness or, at minimum, that working conditions increased the risk of contracting it. The Court cited Raro v. Employees Compensation Commission for the proposition that the law requires the claimant to prove a positive fact—that the illness was caused by employment and that the risk of contracting the disease was increased by the working conditions—and that proof cannot be supplied by presumption where none exists.

The Court further emphasized its treatment of cancers as diseases of generally unknown origin that may afflict people regardless of employment, stating that without proof linking a particular form of cancer to specific working conditions, the conclusion that employment increased the risk cannot be drawn. It treated this reasoning as analogous support for the necessity of proof in the case before it.

Applying those principles, the Court held that petitioner had not shown how the work of a public school teacher—even if underpaid and difficult—created natural hazards that would cause the particular liver ailment. The Court treated cirrhosis of the liver as a disease to which mankind in general was exposed or afflicted, regardless of the nature of one’s work. It therefore concluded that the illness was not caused by hard work in the sense required to establish work-connection. The Court reasoned that the possibility that a person with better access to

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