DOMNA VILLAVERT, PETITIONER, EMPLOYEES’ COMPENSATION COMMISSION & GOVERNMENT SERVICE INSURANCE SYSTEM (PHILIPPINE CONSTABULARY), RESPONDENTS.

Villavert versus Employees' Compensation Commission

The Case

This is a petition for review of a decision of the Employees' Compensation Commission, brought by Domna Villavert, the mother of a deceased government employee, against the Commission and the Government Service Insurance System, which acts for the Philippine Constabulary. The petitioner seeks death benefits under the Employees' Compensation law, Presidential Decree Number 626, as amended, after her son died of acute hemorrhagic pancreatitis. The case matters because it shows how the Court treats a claim for a disease that is not on the official list of occupational diseases, and how it applies the rule that doubts in labor law are resolved in favor of the worker.

Procedural History

The petitioner filed her claim for income benefits with the Government Service Insurance System, which denied it on the ground that acute hemorrhagic pancreatitis is not an occupational disease and that no causal connection had been shown between the fatal ailment and the nature of the employment. She appealed to the Employees' Compensation Commission, which affirmed the denial. She then came to the Supreme Court on a petition to review the Commission's decision. The Supreme Court set aside the Commission's decision and ordered the payment of death benefits.

Facts

Marcelino Villavert was employed as a Code Verifier in the Philippine Constabulary. Because of a shortage of civilian personnel, he also performed the duties of a computer operator and a clerk typist. On the morning of December 11, 1975, he reported as usual to the Constabulary Computer Center at Camp Crame, Quezon City. He worked the whole day, and although he was already complaining of chest pain and headache late in the afternoon, he was still required to render overtime service until late in the evening, typing voluminous classified communications, computing allowances, and preparing checks for the salaries of Philippine Constabulary and Integrated National Police personnel throughout the country, for distribution on or before December 15, 1975.

He went home late at night and, because of fatigue, went to bed without taking his meal. Shortly thereafter, his mother noticed him gasping for breath, perspiring profusely, and mumbling incoherent words. She rushed him to the hospital, where he was pronounced dead at 5:30 in the morning of December 12, 1975, without regaining consciousness. The cause of death was acute hemorrhagic pancreatitis.

To support her claim, the petitioner submitted the certification of the commanding officer of the Philippine Constabulary, stating that the deceased had been subjected to excessive heat and cold as a computer operator, had taken his meals irregularly and late, had performed rotation duties leaving him insufficient time for routine physical check-ups, and had never drunk liquor, smoked, or engaged in immoral habits. This was corroborated by the affidavit of the Chief Clerk of the Computer Center. The Government Service Insurance System and the Commission nevertheless denied the claim, citing medical literature associating the disease with alcoholism, biliary tract disease, drugs, and trauma. The Medico Legal Officer of the National Bureau of Investigation, however, stated that the exact cause of the disease is still unknown, although most research data agree that physical and mental stresses are strong causal factors.

Issues

• Whether or not the death of Marcelino Villavert from acute hemorrhagic pancreatitis was caused or at least aggravated by the duties he performed as code verifier, computer operator, and clerk typist of the Philippine Constabulary.
• Whether or not the petitioner is entitled to death benefits under Presidential Decree Number 626, as amended.

Applicable Provisions

Article 4 of the Labor Code of the Philippines, as amended, provides:

All doubts in the implementation and interpretation of this Code, including its implementing rules and regulations shall be resolved in favor of labor.

This provision bears on the case because the Court used it to resolve the doubt about causation in favor of the worker's mother.

Ruling

On the first issue, the Court held that Marcelino Villavert died of acute hemorrhagic pancreatitis which was directly caused or at least aggravated by the duties he performed as code verifier, computer operator, and clerk typist. The Court noted that there was no evidence at all that he had a bout of alcoholic intoxication shortly before he died, and no showing that he used drugs. The medical literature cited by the Commission merely listed possible causes; it did not exclude the stresses of his work. The Court gave weight to the certification and affidavit describing his excessive workload, irregular meals, exposure to heat and cold, and over fatigue.

On the second issue, the Court resolved the doubt in favor of the worker, applying Article 4 of the Labor Code, and held that the petitioner was entitled to death benefits.

Doctrine

A disease need not be listed as an occupational disease for a claim to prosper, so long as the evidence shows that the risk of contracting it was increased by the working conditions, or that the illness was caused or at least aggravated by the nature of the employment. Where the medical evidence does not exclude the stresses of the work as a cause, and the record shows excessive workload and fatigue, the doubt must be resolved in favor of labor under Article 4 of the Labor Code. The employer's own certifications and affidavits describing the working conditions may support the claim.

Disposition

The Court set aside the decision of the Employees' Compensation Commission and ordered the Government Service Insurance System to pay the petitioner death benefits in the amount of six thousand pesos.

Remember This

The single line worth memorizing is that all doubts in the implementation and interpretation of the Labor Code are resolved in favor of labor, and that a non-occupational disease may still be compensable if the working conditions caused or aggravated it. Examiners like to use this case to test the application of the doubt-resolved-in-favor-of-labor rule to employees' compensation claims.