CASE DIGEST: CAROLINA CLEMENTE vs. GSIS. G.R. No. L-47521. July 31, 1987

Art. 4 - On Construction of Labor Code

FACTS:

Petitioner's husband Pedro Clemente was a janitor in the DOH Dagupan, assigned at the Ilocos Norte Skin Clinic, Laoag City  for 10 years. He was hospitalized due to his ailment of "Nephritis". He was also found to be suffering from Hansen's Disease. Because of uremia due to nephritis, Pedro died and thereafter, his wife petitioner filed with GSIS a claim for employees' compensation under the the Labor Code, as amended.

Petitioner allege that his work as a janitor, having direct contact with persons suffering from different kind of skin diseases and was exposed to obnoxious dusts and other dirt contributed to his ailment of Hansen's disease.

GSIS denied the claim contending that her husband's ailments are not listed as occupational diseases; that there was no substantial evidence of causal connection; and that, in fact, the evidence was that the deceased had already contracted the Hansen's disease before his employment.

ISSUE:

Whether petitioner may claim compensation to GSIS based on mere substantial evidence on record.

RULING:

Yes, strict rules of evidence are not applicable in claims for compensation. There is no stringent criteria to follow. The degree of proof required under P.D. 6266 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. There must be at least reasonable work connection and not a direct causal relation. 

In this case, the court find sufficient evidence on record to sustain the petitioner's view. The records and medical reports shows that the major ailments of his husband's diseases can be traced from bacterial and viral infections.

Definitely, in this case the court find that reasonable work connection between the nature of the job of the petitioner's husband and the diseases he suffered. It is not unreasonable to conclude that his working conditions increased the risk of his contracting the said ailments.

In a case like this, liberal interpretation of the labor code must be in favor of the workers. That in case of doubt in the interpretation-like in the appreciation of evidence in this case-the construction must always favors the worker.