SC on liberality in favor of employees in compensation claims

Social Security System v. Violeta A. Simacas

G.R. No. 217866 | June 20, 2022 | Leonen, J.:

FACTS:

Irnido L. Simacas (Irnido) was a Fabrication Helper at Fieldstar Manufacturing Corporation (Fieldstar) for 15 years where he assisted the welder and machinist in cutting steel materials. He was retired by Fieldstar in February 2010 as he was no longer able to perform his job due to his worsening back pains and incessant coughing which started in 2008.

On February 20, 2010, Irnido was hospitalized and diagnosed with Benign Prostatic Hypertrophy (BHP) TIC (to consider) Prostatic Cancer and Pneumonia vs. Pulmonary Tuberculosis. Just months later, he was again hospitalized due to severe chest and back pains as well as difficulty in breathing. He died on July 13, 2010 due to Cardiopulmonary Arrest probably secondary to Metastatic Prostatic Adenocarcinoma.

Violeta A. Simacas (Violeta), Irnido's surviving spouse, filed a claim for employees' compensation benefits under Presidential Decree No. 626. Social Security System (SSS) Sta. Maria Branch denied the claim on the ground that the cause of Irnido's death was a non-occupational disease. SSS’ Medical Operations Department (MOD) upheld the denial adding that prostatic adenocarcinoma or prostate cancer had no causal relationship with Irnido's job as a fabrication helper.

On May 21, 2012, SSS MOD elevated the case to the Employees Compensation Commission which also affirmed the denial ruling that since prostate cancer is a non-occupational disease, Violeta was required to prove that Irnido's work increased the risk of him contracting prostate cancer.

Aggrieved, Violeta appealed before the Court of Appeals (CA) which reversed the Commission’s decision.

According to the CA, Presidential Decree No. 626 is a social legislation designed to protect workers from loss of income by reason of the hazards of disability and illness. It underscored that for this purpose to be realized, the implementing authorities must adopt a liberal attitude in deciding compensability claims

The CA applied Government Service Insurance System v. Court of Appeals and held that it was impossible for Violeta to present evidence of causal relation since the specific cause for prostate cancer is medically unknown. It decreed that given the present state of scientific knowledge, "the obligation to present such impossible evidence must, therefore, be deemed void. The Social Security System moved for reconsideration, but it was denied by the CA on April 8, 2015.

Dissatisfied, SSS filed a Petition for Review before the Supreme Court.

ISSUE:

Was Violeta able to discharge the burden of proving compensability despite the lack of direct causal relation between prostate cancer as Irnido’s cause of death and his work or working conditions as a Fabrication Helper?

HELD:

Yes. P.D. 626 only requires a reasonable work-connection, not a direct causal relation.

In establishing compensability, the claimant need only present substantial proof that the nature of the deceased's work or working conditions increased the risk of them contracting prostate cancer. In Sarmiento v. Employees' Compensation Commission, the Court held that strict rules of evidence are not applicable in claims for compensation. There are no stringent criteria to follow. The degree of proof required under P.D. 626, is merely substantial evidence, which means, such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.

Still quoting Sarmiento, the Court held that 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 the law requires is a reasonable work-connection and not a direct causal relation. It is enough that the hypothesis on which the workmen's claim is based is probable. Medical opinion to the contrary can be disregarded especially where there is some basis in the facts for inferring a work-connection. Probability not certainty is the touchstone.

In the present case, Violeta was able to prove by substantial evidence that Irnido’s working conditions increased the risk of his contracting prostate cancer.

The established risk factors for prostate cancer are advanced age, ethnicity, genetic factors and family history. However, several studies have suggested that work-related exposures to certain substances, such as chromium, have the potential of affecting the risk of getting prostate cancer. A recent study revealed a small but significant increase in prostate cancer risk for chromium exposure.

Irnido is exposed to chromium due to the nature of his work. It is undisputed that his work included assisting the welder and machinist in cutting steel materials. It is said that workers engaged in the manufacturing or handling of stainless steel are exposed to chromium in varying degrees. Thus, it is not unlikely that Imido's work increased the risk of him contracting the disease. This probability suffices to warrant the grant of the claimed benefits.

The Court stressed that while Presidential Decree No. 626 has not incorporated the presumption of compensability and the theory of aggravation prevalent under the 'Workmen's Compensation Act, it continues to be an employees' compensation law or social legislation that should be liberally construed in favor of labor.

Petition denied.