In cases of non-occupational diseases, proving that an employee’s working conditions significantly increased the risk of contracting the illness is crucial for compensation claims. The Supreme Court has reiterated that while a direct causal relationship isn’t necessary, there must be substantial evidence establishing a reasonable connection between the work and the disease. This principle ensures that employees are protected when their work environment contributes to their health issues.

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This case revolves around Violeta A. Simacas’s claim for death benefits following the death of her husband, Irnido L. Simacas, from metastatic prostatic adenocarcinoma. Irnido worked as a Fabrication Helper at Fieldstar Manufacturing Corporation, where he assisted in cutting steel materials. After his death, Violeta sought employee compensation, arguing that Irnido’s working conditions contributed to his illness. The Social Security System (SSS) denied her claim, stating that prostate cancer is a non-occupational disease with no direct link to Irnido’s job.

The Employees Compensation Commission (ECC) supported SSS’s decision, requiring Violeta to prove that Irnido’s work increased his risk of developing prostate cancer, which she failed to do in their assessment. On appeal, the Court of Appeals (CA) reversed the ECC’s ruling, citing the social justice principle of Presidential Decree No. 626. The CA highlighted the difficulty of proving direct causation due to the unknown specific causes of prostate cancer, relying on the principle that such an impossible evidentiary burden should not stand.

The Supreme Court addressed whether Violeta was entitled to death benefits under Presidential Decree No. 626, as amended. The court acknowledged the general rule that only questions of law should be raised in a petition for review. However, it noted exceptions, particularly when the Court of Appeals’ factual findings differ from those of the petitioner and the Employees Compensation Commission. Such conflicting findings warranted a reevaluation of the evidence.

The Court emphasized that to be compensable, the sickness or resulting death must stem from a listed occupational disease, as defined by the Labor Code and the Implementing Rules of Presidential Decree No. 626. However, if the illness is non-occupational, it must be proven that the risk of contracting the disease was increased by working conditions. In this case, since prostate cancer is not a listed occupational disease, Violeta needed to demonstrate that Irnido’s work environment heightened his risk.

The standard of proof for establishing compensability requires only substantial evidence that the nature of the deceased’s work or working conditions increased the risk of contracting prostate cancer. This principle was highlighted in Sarmiento v. Employees’ Compensation Commission, where the Court held:

Strict rules of evidence are not applicable in claims for compensation. There are no stringent criteria to follow. The degree of proof required under P.D. 626, is merely substantial evidence, which means, “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion”. The claimant must show, at least, by substantial evidence that the development of the disease is brought largely by the conditions present in the nature of the job. What the law requires is a reasonable work-connection and not a direct causal relation. It is enough that the hypothesis on which the workmen’s claim is based is probable. Medical opinion to the contrary can be disregarded especially where there is some basis in the facts for inferring a work-connection. Probability not certainty is the touchstone.

The Supreme Court found that Violeta had indeed proven that Irnido’s working conditions increased his risk of contracting prostate cancer. While the exact etiology of prostate cancer remains largely unknown, established risk factors include age, ethnicity, genetic factors, and family history. Recent studies suggest a correlation between work-related exposures to certain substances like chromium and the increased risk of prostate cancer.

Considering Irnido’s work involved assisting in cutting steel materials, and workers handling stainless steel are exposed to varying degrees of chromium, the Court found it plausible that Irnido’s work elevated his risk. Though a direct causal link wasn’t definitively established, the probability sufficed to warrant the grant of death benefits. The court noted that Presidential Decree No. 626, while not incorporating the presumption of compensability under the Workmen’s Compensation Act, remains a social legislation that should be liberally construed in favor of labor.

The Supreme Court also cited Obra v. Social Security System, emphasizing that the ECC and SSS should adopt a liberal attitude in favor of the employee when deciding claims for compensability, especially if there’s a factual basis for inferring a work connection with the illness or injury. This interpretation aligns with the compassionate spirit of the law, as embodied in Article 4 of the New Labor Code.

FAQs

What was the key issue in this case?	The key issue was whether Violeta Simacas was entitled to death benefits under Presidential Decree No. 626, considering her husband’s death from prostate cancer, a non-occupational disease. The court had to determine if his work conditions increased his risk of contracting the disease.
What is the standard of proof required for compensation claims in the Philippines?	In compensation claims, strict rules of evidence are not applicable. The standard of proof required is merely substantial evidence, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
What does substantial evidence mean in the context of employee compensation?	Substantial evidence refers to relevant evidence that a reasonable person would consider adequate to support a conclusion. It doesn’t require a direct causal relationship, but a reasonable connection between the work and the illness.
What is the significance of Presidential Decree No. 626?	Presidential Decree No. 626 is a social legislation designed to protect workers from loss of income due to disability, illness, or death resulting from work-related causes. It provides for employee compensation benefits.
What are occupational and non-occupational diseases according to the Labor Code?	Occupational diseases are those listed by the Employees Compensation Commission as directly related to specific jobs or industries. Non-occupational diseases are any other illnesses, but can be compensable if proven that the risk of contracting them was increased by working conditions.
Can exposure to certain substances at work increase the risk of contracting diseases like cancer?	Yes, studies suggest that work-related exposures to certain substances, such as chromium in steel manufacturing, can potentially increase the risk of contracting diseases like prostate cancer. This was a crucial factor in the Supreme Court’s decision.
What factors did the court consider in determining the compensability of prostate cancer in this case?	The court considered the nature of Irnido’s work, the potential exposure to substances like chromium, and the existing scientific literature linking such exposures to an increased risk of prostate cancer. It also took into account the social justice principle of liberally construing laws in favor of labor.
What is the role of the Employees Compensation Commission (ECC) and Social Security System (SSS) in compensation claims?	The ECC determines and approves occupational diseases and work-related illnesses that may be considered compensable. The SSS processes and administers employee compensation benefits to eligible claimants.

In conclusion, this case underscores the importance of protecting workers’ rights by ensuring that compensation laws are liberally construed in their favor. By requiring only substantial evidence of a reasonable work connection, the Supreme Court affirms the social justice principle inherent in employee compensation laws, providing a safety net for workers and their families.

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: SOCIAL SECURITY SYSTEM vs. VIOLETA A. SIMACAS, G.R. No. 217866, June 20, 2022