SSS v Violeta Simacas (2022, G.R. No. 217866)

 SSS v. Violeta Simacas

June 20, 2022, G.R. No. 217866

Violeta's husband worked in a factory handling stainless steel. He was diagnosed with prostate cancer and died. Violeta claimed for death benefits which the Commission denied since prostate cancer is not listed as an occupational disease. SC: It suffices to establish that working conditions increased the risk of contracting the disease.

Facts:

Irnido, husband of the appellee (Violeta) was a Fabricaiton Helper at FIELDSTAR from 1995 to 2010. Two years before retiring,  Irnido complained of back pains and incessant coughing. In 2010, he was diagnosed with "Benign Prostatic Hypertrophy (BHP) T/C (to consider) Prostatic Cancer and Pneumonia vs. Pulmonary Tuberculosis." He retired in February 2010, and died in July 2010.

Violeta filed a claim for employee's compensation benefits, denied by SSS (ground: the death was a non-occupational disease). It was ruled that prostatic adenocarcinoma or prostate cancer was not considered an occupational disease.

CA reversed the decision and ordered SSS to pay Violeta's claim for death benefits. Grounds:

• PD 626 is a social legislation that must be liberally interpreted in favor of claims
• It was impossible to present evidence of causal relation since the specific cause for prostate caner is medically unknown.
• "obligation to present such impossible evidence...must, therefore, be deemed void"

Issue: W/N Violeta is entitled to death benefits under PD 626, as amended.

Held: Yes, Violeta is entitled to death benefits. A review of the records reveal that Violeta proved that Irnido's working conditions increased the risk of him contracting prostate cancer.

Violeta cited medical journals stating that work-related exposures to certain substances (e.g. chromium) have the potential of affecting the risk of getting prostate cancer. A study also stated that "workers engaged in the manufacturing or handling stainless steel are exposed to chromium at varying degrees".

Doctrines:

• For a non-occupational disease to be compensable, substantial evidence must be presented to prove that the risk of contracting the illness was aggravated by the employee's working conditions. 
• it suffices to establish that the risk of contracting the disease is increased by the working conditions
• not necessary to show direct causal relation
• "It is enough that the hypothesis on which the 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." (Sarmiento v ECC, 1986)
• Substantial evidence: such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.
• LC defines sickness as: 
• any illness definitely accepted as an occupational disease listed by the Commission, or any illness caused by employment subject to proof that the risk of contracting the same is increased by working conditions.
• If non-occupational disease
• Proof must be shown that the risk of contracting the disease is increased by the working conditions