In Jacang v. Employees’ Compensation Commission, the Supreme Court ruled that when a listed occupational disease contributes to a worker’s death, compensation is warranted, even if a non-listed ailment is also involved. This decision emphasizes that social legislation like P.D. No. 626 should be interpreted in favor of employees, ensuring that workers and their families receive benefits when work-related illnesses contribute to death. This ruling broadens the scope of compensable illnesses, protecting vulnerable employees and setting a precedent for a more compassionate application of labor laws.

From Janitorial Work to Fatal Illness: When Linked Ailments Merit Compensation

The case revolves around Precy Jacang’s claim for death benefits following the death of her husband, Dionisio Jacang. Dionisio, initially hired as a janitor, later worked as a factory worker for Contemporary Services, Inc. He was diagnosed with pulmonary tuberculosis (PTB) during his employment, a condition that worsened over time. Eventually, he was hospitalized and passed away, with the death certificate citing cardiopulmonary arrest, disseminated intravascular coagulopathy (DIC), and Takayasu’s Disease as the causes of death. Precy’s claim for death benefits was initially denied by the Social Security System (SSS) and the Employees’ Compensation Commission (ECC), arguing that Takayasu’s Disease was not work-related. This denial led to a legal battle that ultimately reached the Supreme Court.

The central legal question was whether Dionisio’s death was compensable under Presidential Decree No. 626, as amended, which governs employees’ compensation. The SSS and ECC argued that because Takayasu’s Disease is not listed as an occupational disease, and because Precy failed to prove a direct causal link between Dionisio’s work conditions and the disease, the claim should be denied. However, the Supreme Court took a different view, emphasizing the importance of social justice and the law’s intent to protect employees. Section 1 (b), Rule III, of the Rules Implementing Presidential Decree No. 626, as amended, states that compensability extends to occupational diseases listed, or when the risk of contracting the illness is increased by working conditions.

The Court considered several critical pieces of evidence. First, Dionisio was certified as physically fit when hired. Second, he contracted PTB, a listed occupational disease, during his employment. Third, medical records indicated PTB and its complications contributed to his death. The Court noted that while Takayasu’s Disease itself is not listed, it has scientific links to PTB. The Supreme Court underscored that even if Takayasu’s Disease was the immediate cause of death, the presence of PTB, which is a listed occupational disease, established a basis for compensation. The Court cited prior rulings emphasizing that the incidence of a listed occupational disease, whether or not associated with a non-listed ailment, is sufficient for requiring compensation.

A significant aspect of the Court’s reasoning was the interpretation of P.D. No. 626 as social legislation. The Court emphasized that any doubt should be resolved in favor of the employee, aligning with the law’s purpose of providing social justice. This perspective guided the Court’s assessment of the evidence and its ultimate decision to grant compensation. The Court stated:

Any doubt on this matter has to be interpreted in favor of the employee, considering that P.D. No. 626 is a social legislation. In this case, enough substantial evidence has been shown to convince us that the surviving spouse of the deceased worker is entitled to compensation under said P.D. No. 626, because the records show his ailment and death have been associated with PTB, a listed compensable disease.

The Court further addressed the argument that protecting the State Insurance Fund justified denying the claim. While acknowledging the importance of safeguarding the fund, the Court cautioned against strict protection in borderline cases that could defeat the law’s purpose. The Court highlighted that the fund exists for workers like Dionisio and their dependents, and denying benefits based on a technicality would be a “cruel irony.”

This case illustrates the principle that employees’ compensation laws are interpreted liberally in favor of workers. It underscores that when a listed occupational disease contributes to a worker’s death, compensation is warranted, even if a non-listed ailment is also involved. Furthermore, the decision reinforces the State’s duty to protect workers and their families, ensuring that social legislation serves its intended purpose of providing social justice.

FAQs

What was the key issue in this case?	The key issue was whether the death of Dionisio Jacang, attributed to Takayasu’s Disease but associated with Pulmonary Tuberculosis (PTB), a listed occupational disease, was compensable under P.D. No. 626.
What is Presidential Decree No. 626?	Presidential Decree No. 626, as amended, is the law governing employees’ compensation in the Philippines, providing benefits to employees and their dependents in case of work-related injuries, illnesses, or death.
What is Takayasu’s Disease?	Takayasu’s Disease, also known as Takayasu’s arteritis, is a rare chronic inflammatory disease affecting the aorta and its major branches, leading to weakened arteries and potential complications.
Is Takayasu’s Disease listed as an occupational disease under P.D. No. 626?	No, Takayasu’s Disease is not specifically listed as an occupational disease under P.D. No. 626.
What is Pulmonary Tuberculosis (PTB)?	Pulmonary Tuberculosis (PTB) is an infectious disease caused by the bacterium Mycobacterium tuberculosis, primarily affecting the lungs and potentially leading to severe respiratory complications.
Is PTB considered an occupational disease under P.D. No. 626?	Yes, PTB is listed as an occupational disease under P.D. No. 626, particularly in occupations involving close contact with sources of tuberculosis infection or exposure to harmful substances in the working environment.
What did the Supreme Court rule regarding the compensability of Dionisio’s death?	The Supreme Court ruled that Dionisio’s death was compensable because his PTB, a listed occupational disease, was associated with his death, even though Takayasu’s Disease, a non-listed ailment, was also a contributing factor.
What is the significance of P.D. No. 626 being a social legislation?	As social legislation, P.D. No. 626 is interpreted liberally in favor of employees, meaning any doubts or ambiguities are resolved to protect workers and their families, ensuring they receive the benefits they are entitled to.
What evidence supported the Supreme Court’s decision?	The evidence included Dionisio’s clean bill of health upon hiring, his subsequent PTB diagnosis during employment, the association between PTB and his death, and the SSS Accident/Sickness Report indicating cardiopulmonary arrest (PTB).

In conclusion, this case underscores the importance of interpreting social legislation in favor of the employee. It provides a framework for evaluating claims where a listed occupational disease is associated with a worker’s death, even if a non-listed ailment is also involved, setting a precedent for a more compassionate application of labor laws.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Precy P. Jacang v. ECC and SSS, G.R. No. 151893, October 20, 2005