Lawyerly

GR No. 187474

2013-02-06

GOVERNMENT SERVICE INSURANCE SYSTEM v. MARILOU ALCARAZ

BRION, J.

In her Comment,[10] dated September 24, 2009, Marilou asks that the petition be denied for "utter lack of merit," arguing that the CA did not err in finding that Bernardo's illness was compensable as it was work-related. She takes exception to the GSIS' argument that there was no evidence showing that the nature of Bernardo's work had increased the risk of his contracting myocardial infarction. She maintains that the GSIS failed to consider that while diabetes mellitus does increase the risk of the development of the illness, the same thing is true with CAP, a compensable disease that Bernardo had been earlier diagnosed with. She adds that stress is another predisposing factor for heart diseases as this Court recognized in Government Service Insurance System (GSIS) v. Cuanang.[11] Marilou thus insists that the GSIS erred in singly attributing the occurrence of Bernardo's fatal heart attack to diabetes mellitus, when Bernardo had been suffering from CAP and experiencing physical stress at the same time. She argues further that the Court had previously held that the incidence of acute myocardial infarction, whether or not associated with a non-listed ailment, is enough basis for requiring compensation.[12]

GR No. 185035

2009-07-15

GOVERNMENT SERVICE INSURANCE SYSTEM v. SALVADOR A. DE CASTRO

BRION, J.

We close by reiterating that what the law requires is a reasonable work connection and not direct causal relation.[35] Probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings.[36] For, in interpreting and carrying out the provisions of the Labor Code and its Implementing Rules and Regulations, the primordial and paramount consideration is the employee's welfare. To safeguard the worker's rights, any doubt on the proper interpretation and application must be resolved in favor of labor.[37]

GR No. 160467

2009-04-07

SOLEDAD MUÑOZ MESA v. SOCIAL SECURITY SYSTEM

CARPIO MORALES, J.

[C]laims falling under the Employees' Compensation Act should be liberally resolved to fulfill its essence as a social legislation designed to afford relief to the working man and woman in our society. It is only this kind of interpretation that can give meaning and substance to the compassionate spirit of the law as embodied in Article 4 of the New Labor Code, which states that all doubts in the implementation and interpretation of the provisions of the Labor Code including its implementing rules and regulations should be resolved in favor of labor.[14] (Underscoring supplied)

GR No. 166261

2008-06-27

GOVERNMENT SERVICE INSURANCE SYSTEM v. ASTRID V. CORRALES

AUSTRIA-MARTINEZ, J.

It is sufficient that the foregoing elements be established, not by direct and clear evidence, but by mere substantial evidence or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Thus, for as long as some factual basis exists from which it can be drawn that the disease afflicted the claimant under the third condition, the disability ought to be considered compensable.[43] More importantly, once there is substantial evidence of the existence of such condition, the same cannot be diminished even by medical opinion to the contrary.[44] The yardstick in employees' compensation cases is mere probability, not certainty; thus, whatever doubt such contrary medical opinion may engender should be interpreted in favor of the employees for whom social legislations, like P.D. No. 626, are enacted. [45]

GR No. 172925

2007-10-19

GOVERNMENT SERVICE INSURANCE SYSTEM v. JAIME K. IBARRA

CHICO-NAZARIO, J.

Considering that the nature of petitioner's work entails the preparation of complicated reports and analysis of voluminous documents, stress is hardly a setback that is alien to his profession.[21] What the law requires is a reasonable work connection, and not direct causal relation. It is enough that the hypothesis on which the workman's claim is based is probable.[22] Probability, and not the ultimate degree of certainty, is the test of proof in compensation proceedings.[23] Presidential Decree No. 626, as amended, is indeed said to have abandoned the presumption of compensability and the theory of aggravation prevalent under the Workmen's Compensation Act. Nonetheless, the Supreme Court ruled in Employees' Compensation Commission v. Court of Appeals,[24] that despite the abandonment of the presumption of compensability established by the old law, the present law has not ceased to be an employees' compensation law or a social legislation. Consequently, the presumption in favor of labor still prevails. "Elsewise stated, a humanitarian impulse, dictated by no less than the Constitution itself under the social justice policy, calls for a liberal and sympathetic approach to legitimate appeals of disabled public servants; or that all doubts to the right to compensation must be resolved in favor of the employee or laborer. Verily, the policy is to extend the applicability of the law on employees' compensation to as many employees who can avail of the benefits thereunder."[25]

GR No. 148308

2007-09-21

ROBERTO D. DEBAUDIN v. SOCIAL SECURITY SYSTEM

AZCUNA, J.

Under the Labor Code, as amended, an employee is entitled to compensation benefits if the sickness is a result of an occupational disease listed under Annex "A" of the Rules on Employees' Compensation; or in case of any other illness, if it is caused by employment, subject to proof that the risk of contracting the same is increased by the working conditions.[14] This is as it should be because for an illness to be compensable, it must be (1) directly caused by such employment; (2) aggravated by the employment; or (3) the result of the nature of such employment.[15] Jurisprudence provides that to establish compensability of a non-occupational disease, reasonable proof of work-connection and not direct causal relation is required.[16] It is enough that the hypothesis on which the workmen's claim is based is probable.[17] Probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings[18] since in carrying out and interpreting the provisions of the Labor Code and its implementing rules and regulations the primordial and paramount consideration is the employees' welfare.

GR No. 148308

2007-09-21

ROBERTO D. DEBAUDIN v. SOCIAL SECURITY SYSTEM

AZCUNA, J.

Under the Labor Code, as amended, an employee is entitled to compensation benefits if the sickness is a result of an occupational disease listed under Annex "A" of the Rules on Employees' Compensation; or in case of any other illness, if it is caused by employment, subject to proof that the risk of contracting the same is increased by the working conditions.[14] This is as it should be because for an illness to be compensable, it must be (1) directly caused by such employment; (2) aggravated by the employment; or (3) the result of the nature of such employment.[15] Jurisprudence provides that to establish compensability of a non-occupational disease, reasonable proof of work-connection and not direct causal relation is required.[16] It is enough that the hypothesis on which the workmen's claim is based is probable.[17] Probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings[18] since in carrying out and interpreting the provisions of the Labor Code and its implementing rules and regulations the primordial and paramount consideration is the employees' welfare.

GR NO. 167572

2007-07-27

GOVERNMENT SERVICE INSURANCE SYSTEM v. MELVIN I. PALMA

CHICO-NAZARIO, J.

x x x We find it also probable that [respondent's] chances of developing thyroid cancer was aggravated when he was regularly exposed to chemicals such as muriatic acid and paints which, in turn, caused the constant irritation of his throat.[15] There is no dispute that Presidential Decree No. 626, as amended, abandoned the presumption of compensability and the theory of aggravation prevalent under the Workmen's Compensation Act. Despite such abandonment, however, the present law has not ceased to be an employees' compensation law or a social legislation; hence, the liberality of the law in favor of the working man and woman still prevails, and the official agency charged by law to implement the constitutional guarantee of social justice should adopt a liberal attitude in favor of the employee in deciding claims for compensability, especially in light of the compassionate policy towards labor which the 1987 Constitution vivifies and enhances.[16] Moreover, we are not talking here of mere presumption or theory, but probabilities based on substantial proofs.

GR NO. 166556

2006-07-31

GOVERNMENT SERVICE INSURANCE SYSTEM v. LUZ M. BAUL

CALLEJO, SR., J.

The degree of proof required to validate the concurrence of the above-mentioned conditions under P.D. No. 626 is merely substantial evidence, that is, such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. What the law requires is a reasonable work-connection and not direct causal relation. It is enough that the hypothesis on which the workmen's claim is based is probable.[14] As correctly pointed out by the CA, probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings.[15] For, in interpreting and carrying out the provisions of the Labor Code and its Implementing Rules and Regulations, the primordial and paramount consideration is the employee's welfare. To safeguard the worker's rights, any doubt as to the proper interpretation and application must be resolved in their favor.[16]

GR NO. 166556

2006-07-31

GOVERNMENT SERVICE INSURANCE SYSTEM v. LUZ M. BAUL

CALLEJO, SR., J.

In the instant case, medical reports and drug prescriptions of respondent's attending physicians sufficiently support her claim for disability benefits. Neither the GSIS nor the ECC convincingly deny their genuineness and due execution. The reports are made part of the record and there is no showing that they are false or erroneous, or resorted to as a means of deceiving the Court, hence, are entitled to due probative weight. The failure of respondent to submit to a full medical examination, as required by the rules, to substantiate her essential hypertension, is of no moment. The law is that laboratory reports such as X-ray and ECG are not indispensable prerequisites to compensability,[17] the reason being that the strict rules of evidence need not be observed in claims for compensation.[18] Medical findings of the attending physician may be received in evidence and used as proof of the fact in dispute.[19] The doctor's certification as to the nature of claimant's disability may be given credence as he or she normally would not make untruthful certification. Indeed, no physician in his right mind and who is aware of the far reaching and serious effect that his or her statements would cause on a money claim against a government agency would vouch indiscriminately without regarding his own interests and protection.[20]

	GR No. 187474 2013-02-06	GOVERNMENT SERVICE INSURANCE SYSTEM v. MARILOU ALCARAZ BRION, J.
In her Comment,[10] dated September 24, 2009, Marilou asks that the petition be denied for "utter lack of merit," arguing that the CA did not err in finding that Bernardo's illness was compensable as it was work-related. She takes exception to the GSIS' argument that there was no evidence showing that the nature of Bernardo's work had increased the risk of his contracting myocardial infarction. She maintains that the GSIS failed to consider that while diabetes mellitus does increase the risk of the development of the illness, the same thing is true with CAP, a compensable disease that Bernardo had been earlier diagnosed with. She adds that stress is another predisposing factor for heart diseases as this Court recognized in Government Service Insurance System (GSIS) v. Cuanang.[11] Marilou thus insists that the GSIS erred in singly attributing the occurrence of Bernardo's fatal heart attack to diabetes mellitus, when Bernardo had been suffering from CAP and experiencing physical stress at the same time. She argues further that the Court had previously held that the incidence of acute myocardial infarction, whether or not associated with a non-listed ailment, is enough basis for requiring compensation.[12]
	GR No. 185035 2009-07-15	GOVERNMENT SERVICE INSURANCE SYSTEM v. SALVADOR A. DE CASTRO BRION, J.
We close by reiterating that what the law requires is a reasonable work connection and not direct causal relation.[35] Probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings.[36] For, in interpreting and carrying out the provisions of the Labor Code and its Implementing Rules and Regulations, the primordial and paramount consideration is the employee's welfare. To safeguard the worker's rights, any doubt on the proper interpretation and application must be resolved in favor of labor.[37]
	GR No. 160467 2009-04-07	SOLEDAD MUÑOZ MESA v. SOCIAL SECURITY SYSTEM CARPIO MORALES, J.
[C]laims falling under the Employees' Compensation Act should be liberally resolved to fulfill its essence as a social legislation designed to afford relief to the working man and woman in our society. It is only this kind of interpretation that can give meaning and substance to the compassionate spirit of the law as embodied in Article 4 of the New Labor Code, which states that all doubts in the implementation and interpretation of the provisions of the Labor Code including its implementing rules and regulations should be resolved in favor of labor.[14] (Underscoring supplied)
	GR No. 166261 2008-06-27	GOVERNMENT SERVICE INSURANCE SYSTEM v. ASTRID V. CORRALES AUSTRIA-MARTINEZ, J.
It is sufficient that the foregoing elements be established, not by direct and clear evidence, but by mere substantial evidence or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Thus, for as long as some factual basis exists from which it can be drawn that the disease afflicted the claimant under the third condition, the disability ought to be considered compensable.[43] More importantly, once there is substantial evidence of the existence of such condition, the same cannot be diminished even by medical opinion to the contrary.[44] The yardstick in employees' compensation cases is mere probability, not certainty; thus, whatever doubt such contrary medical opinion may engender should be interpreted in favor of the employees for whom social legislations, like P.D. No. 626, are enacted. [45]
	GR No. 172925 2007-10-19	GOVERNMENT SERVICE INSURANCE SYSTEM v. JAIME K. IBARRA CHICO-NAZARIO, J.
Considering that the nature of petitioner's work entails the preparation of complicated reports and analysis of voluminous documents, stress is hardly a setback that is alien to his profession.[21] What the law requires is a reasonable work connection, and not direct causal relation. It is enough that the hypothesis on which the workman's claim is based is probable.[22] Probability, and not the ultimate degree of certainty, is the test of proof in compensation proceedings.[23] Presidential Decree No. 626, as amended, is indeed said to have abandoned the presumption of compensability and the theory of aggravation prevalent under the Workmen's Compensation Act. Nonetheless, the Supreme Court ruled in Employees' Compensation Commission v. Court of Appeals,[24] that despite the abandonment of the presumption of compensability established by the old law, the present law has not ceased to be an employees' compensation law or a social legislation. Consequently, the presumption in favor of labor still prevails. "Elsewise stated, a humanitarian impulse, dictated by no less than the Constitution itself under the social justice policy, calls for a liberal and sympathetic approach to legitimate appeals of disabled public servants; or that all doubts to the right to compensation must be resolved in favor of the employee or laborer. Verily, the policy is to extend the applicability of the law on employees' compensation to as many employees who can avail of the benefits thereunder."[25]
	GR No. 148308 2007-09-21	ROBERTO D. DEBAUDIN v. SOCIAL SECURITY SYSTEM AZCUNA, J.
Under the Labor Code, as amended, an employee is entitled to compensation benefits if the sickness is a result of an occupational disease listed under Annex "A" of the Rules on Employees' Compensation; or in case of any other illness, if it is caused by employment, subject to proof that the risk of contracting the same is increased by the working conditions.[14] This is as it should be because for an illness to be compensable, it must be (1) directly caused by such employment; (2) aggravated by the employment; or (3) the result of the nature of such employment.[15] Jurisprudence provides that to establish compensability of a non-occupational disease, reasonable proof of work-connection and not direct causal relation is required.[16] It is enough that the hypothesis on which the workmen's claim is based is probable.[17] Probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings[18] since in carrying out and interpreting the provisions of the Labor Code and its implementing rules and regulations the primordial and paramount consideration is the employees' welfare.
	GR No. 148308 2007-09-21	ROBERTO D. DEBAUDIN v. SOCIAL SECURITY SYSTEM AZCUNA, J.
Under the Labor Code, as amended, an employee is entitled to compensation benefits if the sickness is a result of an occupational disease listed under Annex "A" of the Rules on Employees' Compensation; or in case of any other illness, if it is caused by employment, subject to proof that the risk of contracting the same is increased by the working conditions.[14] This is as it should be because for an illness to be compensable, it must be (1) directly caused by such employment; (2) aggravated by the employment; or (3) the result of the nature of such employment.[15] Jurisprudence provides that to establish compensability of a non-occupational disease, reasonable proof of work-connection and not direct causal relation is required.[16] It is enough that the hypothesis on which the workmen's claim is based is probable.[17] Probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings[18] since in carrying out and interpreting the provisions of the Labor Code and its implementing rules and regulations the primordial and paramount consideration is the employees' welfare.
	GR NO. 167572 2007-07-27	GOVERNMENT SERVICE INSURANCE SYSTEM v. MELVIN I. PALMA CHICO-NAZARIO, J.
x x x We find it also probable that [respondent's] chances of developing thyroid cancer was aggravated when he was regularly exposed to chemicals such as muriatic acid and paints which, in turn, caused the constant irritation of his throat.[15] There is no dispute that Presidential Decree No. 626, as amended, abandoned the presumption of compensability and the theory of aggravation prevalent under the Workmen's Compensation Act. Despite such abandonment, however, the present law has not ceased to be an employees' compensation law or a social legislation; hence, the liberality of the law in favor of the working man and woman still prevails, and the official agency charged by law to implement the constitutional guarantee of social justice should adopt a liberal attitude in favor of the employee in deciding claims for compensability, especially in light of the compassionate policy towards labor which the 1987 Constitution vivifies and enhances.[16] Moreover, we are not talking here of mere presumption or theory, but probabilities based on substantial proofs.
	GR NO. 166556 2006-07-31	GOVERNMENT SERVICE INSURANCE SYSTEM v. LUZ M. BAUL CALLEJO, SR., J.
The degree of proof required to validate the concurrence of the above-mentioned conditions under P.D. No. 626 is merely substantial evidence, that is, such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. What the law requires is a reasonable work-connection and not direct causal relation. It is enough that the hypothesis on which the workmen's claim is based is probable.[14] As correctly pointed out by the CA, probability, not the ultimate degree of certainty, is the test of proof in compensation proceedings.[15] For, in interpreting and carrying out the provisions of the Labor Code and its Implementing Rules and Regulations, the primordial and paramount consideration is the employee's welfare. To safeguard the worker's rights, any doubt as to the proper interpretation and application must be resolved in their favor.[16]
	GR NO. 166556 2006-07-31	GOVERNMENT SERVICE INSURANCE SYSTEM v. LUZ M. BAUL CALLEJO, SR., J.
In the instant case, medical reports and drug prescriptions of respondent's attending physicians sufficiently support her claim for disability benefits. Neither the GSIS nor the ECC convincingly deny their genuineness and due execution. The reports are made part of the record and there is no showing that they are false or erroneous, or resorted to as a means of deceiving the Court, hence, are entitled to due probative weight. The failure of respondent to submit to a full medical examination, as required by the rules, to substantiate her essential hypertension, is of no moment. The law is that laboratory reports such as X-ray and ECG are not indispensable prerequisites to compensability,[17] the reason being that the strict rules of evidence need not be observed in claims for compensation.[18] Medical findings of the attending physician may be received in evidence and used as proof of the fact in dispute.[19] The doctor's certification as to the nature of claimant's disability may be given credence as he or she normally would not make untruthful certification. Indeed, no physician in his right mind and who is aware of the far reaching and serious effect that his or her statements would cause on a money claim against a government agency would vouch indiscriminately without regarding his own interests and protection.[20]

GOVERNMENT SERVICE INSURANCE SYSTEM v. TEODOSIO CUANANG