Case Summary (G.R. No. 217866)
Procedural History and Relief Sought
Irnido retired in February 2010 and died on July 13, 2010. His surviving spouse, Violeta, filed a claim for employees’ compensation death benefits under Presidential Decree No. 626, as amended. The SSS branch and its Medical Operations Department denied the claim as non-occupational. The ECC affirmed the denial on July 27, 2012. The CA reversed the ECC and ordered payment of benefits. The SSS filed a Petition for Review on Certiorari to the Supreme Court, which denied the petition and affirmed the CA’s decision.
Facts Relevant to the Claim
Material Facts Regarding Employment, Illness, and Cause of Death
Irnido worked assisting welders and machinists, cutting and handling steel materials and occasionally performing welding and procurement tasks. Two years before retirement he had worsening back pain and cough; he was treated by Intellicare and later hospitalized in February 2010 with diagnoses including benign prostatic hypertrophy (to consider prostatic cancer) and possible pulmonary tuberculosis; he had been on tuberculosis medication and had hepatitis A. He was again hospitalized months later for severe chest/back pain and dyspnea. Death occurred July 13, 2010; the death certificate listed cardiopulmonary arrest probably secondary to metastatic prostatic adenocarcinoma (prostate cancer).
Grounds for Denial and SSS Position
SSS’s Rationale for Denying Compensation
SSS denied the claim on the ground that prostate cancer is a non-occupational disease and that claimant failed to prove that decedent’s work increased the risk of contracting prostate cancer. The SSS Medical Operations Department maintained that prostate cancer is not listed as an occupational disease and that no causal relationship was shown between decedent’s duties as a fabrication helper and the disease.
Claimant’s Position and Evidence of Work Connection
Claimant’s Contentions and Factual Assertions
Violeta argued that P.D. No. 626 should be liberally construed for the protection of labor and that, given the limits of scientific knowledge about prostate cancer causation, it was impossible for her to present direct proof of causation. She asserted that Irnido’s duties involved strenuous handling of heavy steel, cramped and poorly ventilated workspaces, and exposure to conditions associated with welders and metal handling—circumstances that could have aggravated or increased his risk of prostate cancer. She relied on studies suggesting occupational exposures (e.g., chromium) may increase prostate cancer risk.
Legal Standard for Compensability under P.D. No. 626
Statutory and Regulatory Framework for Occupational Sickness
Under the Labor Code definition (art. 173(1)) and the Implementing Rules of P.D. No. 626 (Amended Rules on Employees’ Compensation, Rule III, sec. 1(b)), a sickness not listed as an occupational disease is compensable only upon proof that the risk of contracting it was increased by working conditions. The degree of proof required is substantial evidence establishing a reasonable work connection—not direct causation. The Sarmiento standard governs: a reasonable, probable work-connection suffices; probability, not certainty, is the touchstone; strict rules of evidence are relaxed in compensation claims.
Court’s Analysis of Medical Evidence and Occupational Risk
Evaluation of Medical Knowledge, Risk Factors, and Occupational Exposure
The Court acknowledged that prostate cancer’s etiology is not well established; recognized established risk factors (age, ethnicity, genetics) but also noted studies suggesting a small but significant association between chromium exposure and increased prostate cancer risk. Given the undisputed facts that decedent assisted in cutting and handling steel—an industry where workers encounter chromium—the Court found a plausible increased risk stemming from his working conditions. The Court treated such probability, supported by factual circumstances and scientific literature cited in the record, as sufficient under P.D. No. 626’s standard.
On Reviewability of Factual Findings
Scope of Supreme Court Review of Factual Findings
The Court reiterated the general rule that its review is limited to questions of law and that CA factual findings are binding when supported by substantial evidence, but it recognized established exceptions (as enumerated in Medina v. Asistio, Jr.). Because the CA’s findings conflicted with those of SSS and the ECC, and given the factual controversy over work conditions and risk, the Supreme Court proce
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Procedural History
- Petition for Review on Certiorari to the Supreme Court from the Court of Appeals Decision (August 29, 2014) and Resolution (April 8, 2015) which had reversed the Employees’ Compensation Commission’s denial of respondent’s claim for death benefits under Presidential Decree No. 626, as amended.
- Initial claim for employees’ compensation benefits filed by respondent Violeta A. Simacas after the death of her husband, Irnido L. Simacas, was denied by the Social Security System (SSS) Sta. Maria Branch on the ground that the cause of death was a non-occupational disease.
- SSS Medical Operations Department also denied the claim, ruling that prostatic adenocarcinoma (prostate cancer) was not an occupational disease and had no causal relationship with the deceased’s job; the case was elevated to the Employees’ Compensation Commission (ECC) on May 21, 2012.
- ECC, in its July 27, 2012 decision, affirmed denial of the claim, holding that since prostate cancer is a non-occupational disease, respondent had to prove that the risk of contracting the disease was increased by working conditions, and that respondent failed to present such evidence.
- Respondent appealed to the Court of Appeals; the Court of Appeals reversed the ECC and ordered SSS to pay death benefits, applying a liberal construction of PD No. 626 and relying on precedent that made proof of specific causal relation impracticable in some diseases.
- SSS’s motion for reconsideration before the Court of Appeals was denied on April 8, 2015.
- SSS filed a Petition for Review before the Supreme Court; parties filed comments, replies, memoranda, and a manifestation (respondent later adopted her comment and did not file a memorandum).
- The Supreme Court, in the decision penned by Justice Leonen (Second Division), denied the Petition and affirmed the Court of Appeals’ Decision and Resolution on June 20, 2022.
Factual Background
- Irnido L. Simacas worked as a Fabrication Helper at Fieldstar Manufacturing Corporation from April 1995 until February 2010, assisting the welder and machinist in cutting steel materials.
- Two years before retirement, Irnido complained of back pains and incessant coughing; he sought assessment from Fieldstar’s health care provider, Intellicare, which cleared him for work after assessment, but his symptoms later worsened until he could no longer perform his job and was retired by Fieldstar in February 2010.
- On February 20, 2010, Irnido was hospitalized for back pains, cough, dysuria (painful urination), night sweating, and fever; he was diagnosed “with Benign Prostatic Hypertrophy (BPH) T/C (to consider) Prostatic Cancer and Pneumonia vs. Pulmonary Tuberculosis.”
- At the time of hospitalization, he had been taking medication for Pulmonary Tuberculosis for a month and had also been diagnosed with Hepatitis A.
- Months later he was again admitted due to severe chest and back pains and difficulty in breathing.
- On July 13, 2010, Irnido died at the Philippine Orthopedic Center; his death certificate stated the immediate cause of death as Cardiopulmonary Arrest probably secondary to Metastatic Prostatic Adenocarcinoma.
- Respondent alleged working conditions that included strenuous lifting of heavy steel and metal materials and equipment, buying parts and supplies, occasional welding tasks, and working in a cramped, crowded, and poorly ventilated area.
Issues Presented for Resolution
- Whether factual questions may be resolved in the Petition for Review on Certiorari.
- Whether respondent Violeta A. Simacas is entitled to death benefits under Presidential Decree No. 626, as amended, for the death of her husband.
Relevant Statutory and Rule Provisions
- Labor Code, Title II, ch. 1, art. 173(1): defines “sickness” as any illness definitely accepted as an occupational disease listed by the Commission, or any illness caused by employment subject to proof that the risk of contracting the same is increased by working conditions; grants the Commission power to determine and approve occupational diseases and work-related illnesses compensable based on peculiar hazards of employment.
- Amended Rules on Employees’ Compensation (2014), Rule III, sec. 1(b): for sickness and resulting disability or death to be compensable, the sickness must be an occupational disease listed under Annex “A” of the Rules; otherwise, proof must be shown that the risk of contracting the disease is increased by working conditions.
- Presidential Decree No. 626 (employees’ compensation law) is characterized and treated in the decision as social legislation to be liberally construed in favor of labor.
Burden and Standard of Proof
- Where the illness is not listed as an occupational disease, the claimant must prove that the risk of contracting the disease was increased by working conditions.
- The degree of proof required under PD No. 626 is substantial evidence: “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”
- The claimant must show, at least by substantial evidence, that the development of the disease is brought largely by the conditions present in the nature of the job; what is required is a reasonable work-connection, not a direct causal relation.
- Probability, not certainty, is the touchstone; medical opinion to the contrary can be disregarded when there is some factual basis for inferring a work-connection (as articulated in Sarmiento v. Employees’ Compensation Commission).
Lower Tribunals’ Findings and Reasoning
- SSS Sta. Maria Branch denied the claim as the cause of death was a non-occupational disease.
- SSS Medical Operations Department denied the claim on the basis that pr