GOVERNMENT SERVICE INSURANCE SYSTEM, Petitioner, vs. JEAN E. RAOET, Respondent.

G.R. No. 157038 December 23, 2009

 Respondent’s husband, Francisco, worked in the government from 1974 until 1998 (21 years)
as an engineer in National Irrigation Administration.
 In 2000, Francisco was diagnosed with Hypertension, Severe, Stage III, Coronary Artery
Disease. As the GSIS considered this a work-related condition, Francisco was awarded 30
days Temporary Total Disability benefits, plus reimbursement of medical expenses incurred
during treatment.
 In 2001, he was rushed to the hospital because he was vomiting blood. He was pronounced
dead on arrival.
 In the death certificate, the causes of death are: 1. Cardiac Arrest (immediate cause); 2.
Acute Massive Hemorrhage (antecedent cause); 3. T/C Bleeding Peptic Ulcer Disease
(underlying cause).
 The respondent, as widow, filed with the GSIS a claim for income benefits accruing from the
death of her husband, pursuant to P.D. 626
 GSIS denied the claim on the ground that the respondent did not submit any supporting
documents to show that the underlying cause of Francisco’s death was peptic ulcer.
 On appeal, the Employees Compensation Commission (ECC) affirmed GSIS because it could
not determine whether the death was compensable due to lack of documents supporting the
widow’s claim (no history of consultation for peptic ulcer, no autopsy)
 CA – reversed ECC and ruled that Francisco’s death is compensable even if peptic ulcer is
not a listed occupational disease, since Francisco died due to a listed cause – cardiac arrest.
 On appeal, petitioner GSIS argues that:
 Since the cause of death was peptic ulcer which is not included in the compensable
diseases in the insurance, claimants must show proof that the risk of contracting the
disease was increased by his working conditions. However, claimants failed to do so.
 The deceased’s other ailments (hypertension and coronary artery disease) had
already been awarded benefits which are 30 days Temporary Total Disability benefits
and reimbursement of medical expenses. Hence, no death benefit for the same
diseases can be claimed.
 Finally, GSIS allege that the employees’ compensation trust fund is presently empty,
and claims on this fund are being paid by GSIS from advances coming from its other
funds. Thus, the trust fund would suffer if benefits are paid to claimants who are not
entitled under the law.

ISSUE + RULING: Whether the respondents presented sufficient proof to show that the
underlying cause of Francisco’s death is peptic ulcer

YES. The respondent submitted sufficient proof of the cause of her husband’s death when she
presented his death certificate. In Philippine American Life Insurance Company v. CA, we held
that death certificates and the notes by a municipal health officer prepared in the regular
performance of his duties are prima facie evidence of facts therein stated. A duly-registered
death certificate is considered a public document and the entries found therein are
presumed correct, unless the party who contests its accuracy can produce positive evidence
establishing a contrary conclusion. We also ruled in People v. Datun that a death certificate
establishes the fact of death and its immediate, antecedent, and underlying causes.

ISSUE + RULING: Whether peptic ulcer is a compensable illness

YES. Contrary to the CA’s conclusion, peptic ulcer is a compensable cause of death, pursuant to
ECC Resolution No. 1676, which provides that peptic ulcer is a compensable disease listed
under Annex "A," provided, the claimant is in an occupation that involves prolonged
emotional or physical stress, as among professional people.

ISSUE + RULING: Whether Francisco’s occupation involve prolonged emotional or

physical stress to make his death due to peptic ulcer compensable

YES. In arriving at this conclusion, we stress that in determining the compensability of an illness,
we do not require that the employment be the sole factor in the growth, development, or
acceleration of a claimant’s illness to entitle him to the benefits provided for. It is enough that his
employment contributed, even if only in a small degree, to the development of the disease.
What the law requires is a reasonable work-connection and not a direct causal relation .
Probability, not certainty, is the touchstone.

In this case, Francisco was diagnosed with Hypertension, Severe, Stage III, Coronary Artery
Disease which GSIS found work-connected, hence, it awarded Francisco 30 days Temporary
Total Disability benefits. This shows that the established underlying causes of the combination of
these diseases are, among others, the stressful nature and pressures inherent in an
occupation. The stresses his responsibilities carried did not abate for Francisco when he
returned from his Temporary Total Disability; he occupied the same position without change of
responsibilities until his death. Thus, Francisco had continuous exposure to prolonged emotional
stress that would qualify his peptic ulcer – a stress-driven ailment – as a compensable cause of
death.

P.D. 626 is a social legislation whose primordial purpose is to provide meaningful protection to the
working class against the hazards of disability, illness, and other contingencies resulting in loss of
income. In employee compensation, persons charged by law to carry out the Constitution’s social
justice objectives should adopt a liberal attitude in deciding compensability claims and should not
hesitate to grant compensability where a reasonable measure of work-connection can be inferred.

ISSUE + RULING: Whether depleted state insurance fund is an excuse to avoid payment of
compensation

NO. If the State Insurance Fund lacks the financial capacity, it is not the responsibility of the
insured civil servant, but rather of the State to fill in the deficiency and ensure the solvency of the
State Insurance Fund (Art. 184, LC).

Biscarra vs Republic: “xxx The Republic of the Philippines as a welfare State, in providing for the
social justice guarantee in our Constitution, assumes such risk. Xxx Human beings constitute the
most valuable natural resources of the nation and therefore should merit the highest solicitude
and the greatest protection from the State to relieve them from unbearable agony.”