**Facts:**
– **1955:** Ruben de Leon joined the Philippine Navy, serving primarily as an electrician and repairman.
– **1969:** Ruben was treated for acute tonsillitis by Dr. T. D. Iniguez.
– **1975:** Ruben was diagnosed with pulmonary tuberculosis by Dr. Fortunato Montaos.
– **1976-1978:** Continuous treatment for pulmonary tuberculosis by Dr. Iniguez.
– **May 25, 1978:** Ruben was confined at AFP Medical Center and diagnosed with carcinoma of the nasopharynx. Despite surgery, he succumbed to the disease on September 5, 1978.
– **Post-death:** Diosa de Leon, widow of Ruben, filed a claim for death benefits with the Philippine Navy, which was forwarded to GSIS.
– **December 12, 1979:** GSIS denied the claim, citing no direct causal relationship between Ruben’s employment and his cancer.
– **January 16, 1980:** Diosa filed a motion for reconsideration, which GSIS also denied.
– **Further Appeals:** Diosa’s appeal to the Employees’ Compensation Commission (ECC) was affirmed by ECC on October 23, 1980, dismissing her claim.
– **Petition for Certiorari:** Diosa de Leon petitioned the Supreme Court to review and set aside the ECC’s decision.
**Issues:**
1. **Compensability of Nasopharyngeal Carcinoma:**
– Is cancer of the nasopharynx compensable under Presidential Decree No. 626?
– Is there a causal relationship between Ruben’s employment and his disease?
2. **Applicability of the Old Workmen’s Compensation Act vs. the New Labor Code:**
– Given that the ailment’s onset may be traced back to 1969, should the case be evaluated under the old Workmen’s Compensation Act, given its more beneficial provisions?
**Court’s Decision:**
**1. Compensability of Nasopharyngeal Carcinoma:**
– The Supreme Court ruled in favor of compensability despite medical uncertainty regarding the exact causes of cancer. It cited precedent cases, notably *Dator vs. ECC* and *Cristobal vs. ECC*, emphasizing a liberal interpretation of compensable diseases including various forms of cancer.
– The court emphasized that symptoms such as acute tonsillitis experienced in 1969 and subsequent pulmonary tuberculosis treatments could have been early manifestations of nasopharyngeal carcinoma, undetected due to limitations in medical diagnostics at the time.
– It accepted the argument that Ruben’s consistent exposure to potentially hazardous chemicals in his work environment could have contributed to the development of his cancer, possibly accelerating his vulnerability to the disease.
**2. Applicability of the Old Workmen’s Compensation Act vs. the New Labor Code:**
– Given that Ruben’s ailments likely began before the effectivity of the new Labor Code, the case was adjudicated under the more beneficial provisions of the old Workmen’s Compensation Act. This consistent approach aligns with previous Supreme Court rulings, such as *Calvero vs. ECC* and others.
**Doctrine:**
– **Compensability of Cancer:** Even with unknown etiology, if an ailment manifests during employment and is aggravated by working conditions, it may be deemed compensable. The state’s policy aims to protect and aid workers maximally.
– **Liberal Interpretation:** Favoring the worker in cases of doubt aligns with social justice guarantees.
– **Applicable Law:** Preconditions a favorable approach for workers when the claim period spans changes in statutory law, giving preference to the law’s beneficial provisions active during the pertinent period.
**Class Notes:**
– **Key Elements:**
1. Nature of Employment: Relationship between job duties and ailment.
2. Duration and Documentation: Chronic nature and medical records documenting symptoms.
3. Legal Precedent: Key cases (*Dator vs. ECC*, *Cristobal vs. ECC*, *Bihag vs. WCC*) emphasizing compensability for cancer under unclear etiology.
4. Legal Transition: Old Workmen’s Compensation Act vs. new Labor Code.
– **Statutory Provisions:**
– **Presidential Decree No. 626:** Governs compensability for work-related diseases and outlines conditions under which they can be deemed compensable.
– **Social Justice Provisions:** Constitutional and statutory backing for resolving doubts in favor of the laborer.
**Historical Background:**
– The case reflects the transition period in Philippine labor law from the old Workmen’s Compensation Act to the new Labor Code, highlighting the complexities in compensability determinations during this period. It showcases the judiciary’s role in interpreting and applying evolving laws while upholding the constitutional guarantee to social justice and worker protection. This case is a landmark in understanding how historical shifts in legislative frameworks impact present legal interpretations and rulings.
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