CLARITA SANTIAGO, PETITIONER, VS. EMPLOYEES’ COMPENSATION COMMISSION AND GOVERNMENT SERVICE INSURANCE SYSTEM (BUR. OF ELEM. EDUCATION), RESPONDENTS.

Santiago versus Employees' Compensation Commission

The Case

This is a petition for review of a decision of the Employees' Compensation Commission, brought by Clarita Santiago, a classroom teacher of the Bureau of Elementary Education, against the Commission and the Government Service Insurance System. She sought income benefits under Presidential Decree Number 626, as amended, for a kidney ailment she claimed arose from the nature of her employment. The case matters because it shows how the Court treats the causal link between work and illness when the ailment is not on the list of occupational diseases: compensability may still be established by substantial evidence of an increased risk attributable to the working conditions.

Procedural History

Clarita Santiago filed her claim for income benefits with the Government Service Insurance System, which denied it on the ground that her ailment was not an occupational disease and that the evidence did not show it was the direct result of her occupation. She sought reconsideration, which the System also denied. She then appealed to the Employees' Compensation Commission, which affirmed the denial. From that affirmance she came to the Supreme Court on a petition for certiorari, and the Court reviewed and set aside the Commission's decision.

Facts

Clarita Santiago had been employed as a classroom teacher by the Bureau of Elementary Education since 1956, assigned at the Guerilla Elementary School in Barrio Concepcion, San Pablo City. When first employed she was in good health. Over twenty years of government service her work was not confined to routine classroom activities: she supervised students in out-campus government programs on green revolution and youth civic action, took part in scouting, teachers' seminars and conferences, and community work such as food production, organizing purok and barangay youth, serving as election committee chairman, and attending barangay and parent-teacher meetings. Occasionally she joined co-teachers in house-to-house census visits. Her classroom had no ceiling, so she was exposed to heat from the galvanized iron roof.

Beginning March 25, 1975, she suffered hypogastric and lumbar pains, nausea and vomiting with scanty urination, intermittent fever, and general body malaise. On May 24, 1976, she was admitted to the Good Samaritan Hospital in San Pablo City and discharged without apparent improvement, with the clinical diagnosis of kidney stones, bilateral, pyelonephritis, secondary. Her health deteriorating rapidly, she applied for disability retirement under Republic Act Number 1616.

On July 26, 1976, she filed a claim for income benefits with the Government Service Insurance System, asserting that her ailment was caused by the nature of her employment. The System denied the claim on August 5, 1976, and denied her request for reconsideration by letter dated September 13, 1976. The Employees' Compensation Commission affirmed, reasoning that the primary ailment, staghorn calculi, was not an occupational disease listed under Annex A of the implementing rules, and that her assertion about the heat from the roofing was unsubstantiated and undercut by the absence of any record that her pupils suffered the same ailments.

Issues

• Whether or not the ailment of Clarita Santiago was caused or aggravated by the nature of her employment as a classroom teacher.
• Whether or not her claim for income benefits under Presidential Decree Number 626, as amended, is compensable even though her ailment is not among the listed occupational diseases.

Applicable Provisions

Presidential Decree Number 626, as amended, governs the claim for income benefits, and the decision applies it through the implementing rules, which list the compensable occupational diseases in Annex A:

Annex A of the implementing rules of P.D. No. 626, as amended.

The Court treats this list as not exclusive, so that an ailment outside it may still be compensated upon proof of a causal link to the working conditions.

Ruling

On the first issue, the Court held that the record disclosed facts showing the ailment was caused or aggravated by the nature of her employment. Her out-campus activities could easily have caused the formation of kidney stones, perhaps through inability to urinate regularly; the stones made the kidney susceptible to infection, and the infection resulted in pyelonephritis. The heat in the classroom, which had no ceiling, must also have contributed. On the second issue, the Court held that although the ailment is not listed as a compensable disease, the evidence of record established the causal relation between staghorn calculi, pyelonephritis, and the nature of her work and activities. The Court thus rejected the Commission's demand that the claimant show an increased risk attributable to her employment as a precondition, since the record itself supplied the causal link.

Doctrine

A claim under Presidential Decree Number 626, as amended, is not defeated merely because the ailment is not among the occupational diseases listed in Annex A of the implementing rules. What the law requires is a showing of a causal relation between the ailment and the nature of the work and working conditions, and that causal link may be established by the evidence of record. Where the employee's duties expose her to conditions that can produce or aggravate the illness, compensation may be awarded even for an unlisted disease.

Disposition

The Court set aside the decision of the Employees' Compensation Commission and ordered the Government Service Insurance System to pay twelve thousand pesos as income benefits for permanent total disability and one thousand two hundred pesos as attorney's fees.

Remember This

The single line to memorize: an ailment not listed as an occupational disease is still compensable under Presidential Decree Number 626 when the evidence establishes its causal relation to the nature of the work. Examiners use this case to test the non-exclusiveness of the Annex A list and the substantial-evidence standard for work-relatedness.