Social Security System vs. Violeta A. Simacas

For a non-occupational disease to be compensable under Presidential Decree No. 626, as amended, the claimant need only present substantial evidence of a reasonable work connection showing that the risk of contracting the disease was increased by the employee's working conditions; direct causal relation and certainty are not required.

Violeta A. Simacas is the surviving spouse of Irnido L. Simacas, who worked as a Fabrication Helper at Fieldstar Manufacturing Corporation from April 1995 until February 2010. Presidential Decree No. 626, as amended, governs employees' compensation benefits and is a social legislation; its Implementing Rules distinguish occupational diseases listed under Annex "A" from non-occupational diseases, which require proof that the risk of contracting the disease was increased by working conditions. The Social Security System is the agency that initially evaluates such claims, while the Employees Compensation Commission reviews them.

Irnido L. Simacas worked as a Fabrication Helper at Fieldstar Manufacturing Corporation from April 1995 until February 2010. His duties included assisting the welder and machinist in cutting steel materials. He was married to Violeta A. Simacas, who later sought death benefits after his death. Two years before retiring, Irnido complained of back pains and incessant coughing. He availed the services of Fieldstar's health care provider, Intellicare, which cleared him for work after assessment. His symptoms, however, worsened until he was no longer able to perform his job, and in February 2010 Fieldstar retired him from work.

On February 20, 2010, Irnido was hospitalized due to back pains, cough, dysuria or painful urination, night sweating, and fever. He was diagnosed "with Benign Prostatic Hypertrophy (BHP) T/C (to consider) Prostatic Cancer and Pneumonia vs. Pulmonary Tuberculosis[.]" At the time of hospitalization, he had already been taking medication for Pulmonary Tuberculosis for a month and had also been diagnosed with Hepatitis A. Months later, he was again admitted to the hospital due to severe chest and back pains as well as difficulty in breathing.

On July 13, 2010, Irnido died at the Philippine Orthopedic Center. His death certificate stated that the immediate cause of his death was Cardiopulmonary Arrest probably secondary to Metastatic Prostatic Adenocarcinoma. Violeta, his surviving spouse, filed a claim for employees' compensation benefits. The Social Security System Sta. Maria Branch denied the claim on the ground that the cause of Irnido's death was a non-occupational disease. After further evaluation, the Social Security System's Medical Operations Department also denied the claim, ruling that prostatic adenocarcinoma or prostate cancer was not considered an occupational disease and had no causal relationship with Irnido's job as a fabrication helper. The Medical Operations Department elevated the case to the Employees Compensation Commission on May 21, 2012, and the Commission affirmed the denial on July 27, 2012.

In resolving the claim, the Court of Appeals' factual findings differed from those of petitioner and the Employees Compensation Commission. The Supreme Court noted that it was undisputed that Irnido's work included assisting the welder and machinist in cutting steel materials, and that workers engaged in the manufacturing or handling of stainless steel are exposed to chromium in varying degrees. Respondent also asserted that Irnido's work included strenuous lifting of heavy steel and metal materials and equipment, buying parts and supplies, and performing welding jobs when the welder was unavailable, and that his work area was cramped, crowded, and had little ventilation. The evidence was found sufficient to show that Irnido's working conditions increased the risk of him contracting prostate cancer.

• Non-Occupational Disease and Burden of Proof: Petitioner argued that since prostate cancer is not considered an occupational disease, respondent is obligated to prove that Irnido's work increased the risk of him contracting the disease.
• Absence of Medical Evidence: Petitioner maintained that the absence of medical information demonstrating that Irnido's working conditions caused his prostate cancer renders respondent's claim of work connection untenable.
• Insufficient Basis for Increased-Risk Theory: Petitioner claimed that respondent cannot rely on the increased risk theory considering that there is not enough basis to infer that Irnido's illness is work-related.
• Failure of Substantial Evidence: Petitioner restated that respondent failed to adduce substantial evidence to prove a causal relation between Irnido's work and illness and is not entitled to death benefits since she failed to prove that the risk of contracting the disease was increased by Irnido's working conditions.

• Binding Factual Findings: Respondent contended that the Court of Appeals' factual findings bind the Supreme Court unless the existence of the accepted exceptions is established.
• Liberal Construction: Respondent maintained that claims under Presidential Decree No. 626 should be liberally resolved in favor of labor to realize its purpose as a social legislation.
• Aggravation by Working Conditions: Respondent asserted that while prostate cancer is not an occupational disease, the circumstances surrounding Irnido's death show that his working conditions aggravated the risk of him contracting the disease, citing work that included strenuous lifting of heavy steel and metal materials and equipment, buying of parts and supplies, performing welding jobs in case of the welder's unavailability, and a cramped, crowded work area with little ventilation.
• Impossibility of Causal Proof: Respondent cited the Court's ruling in GSIS and maintained that the insufficiency of scientific knowledge regarding prostate cancer renders it impossible for her to comply with the law's evidentiary requirement.

• Review of Factual Questions: Whether factual questions may be resolved in this Petition for Review on Certiorari.
• Entitlement to Death Benefits: Whether respondent Violeta A. Simacas, spouse of deceased Irnido L. Simacas, is entitled to death benefits under Presidential Decree No. 626, as amended.

• Review of Factual Questions: Yes. Although only questions of law are generally raised in a petition for review, the Court may reevaluate the evidence when the Court of Appeals' factual findings conflict with those of the petitioner and the Employees Compensation Commission.
• Entitlement to Death Benefits: Yes. For a non-occupational disease, substantial evidence of a reasonable work connection suffices; Irnido's steel-cutting work exposed him to chromium, increasing the risk of prostate cancer, and Presidential Decree No. 626 is liberally construed in favor of labor.

• Review of Factual Questions: The general rule is that only questions of law should be raised in a petition for review, and the factual findings of the Court of Appeals are deemed binding and conclusive upon the Supreme Court especially when supported by substantial evidence. As a non-trier of facts, the Supreme Court is not obligated to examine and determine the weight of the evidence supporting the assailed decision. However, the rule admits exceptions. Medina vs. Asistio, Jr. enumerated exceptions, including when the findings of fact are conflicting and when the Court of Appeals' findings are contrary to those of the trial court. Records showed that the Court of Appeals' factual findings differed from those of petitioner and the Employees Compensation Commission. Because of these conflicting findings and conclusion, the Supreme Court could reevaluate the evidence presented by the parties.
• Entitlement to Death Benefits: The Labor Code 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. The Implementing Rules of Presidential Decree No. 626 provide that if the illness is non-occupational, proof must be shown that the risk of contracting the disease is increased by the working conditions. It was undisputed that prostate cancer is not a listed occupational disease, so respondent had to demonstrate that the risk of contracting it was increased by Irnido's working conditions. In Sarmiento vs. Employees' Compensation Commission, the Court held that strict rules of evidence are not applicable in compensation claims; the degree of proof is merely substantial evidence, and what the law requires is a reasonable work-connection, not a direct causal relation. Probability, not certainty, is the touchstone. The Court reviewed the records and found that respondent proved that Irnido's working conditions increased the risk of him contracting prostate cancer. Prostate cancer is characterized by abnormal cells in the prostate that multiply without control or order and form a tumor; while it is a leading cause of death among men, not much is known about its etiology. Established risk factors include advanced age, ethnicity, genetic factors, and family history. However, studies have suggested that work-related exposures to certain substances, such as chromium, have the potential of affecting the risk of getting prostate cancer, and a recent study revealed a small but significant increase in prostate cancer risk for chromium exposure. It was undisputed that Irnido's work included assisting the welder and machinist in cutting steel materials, and workers engaged in the manufacturing or handling of stainless steel are exposed to chromium in varying degrees. Thus, it was not unlikely that Irnido's work increased the risk of him contracting the disease, and this probability sufficed to warrant the grant of the claimed benefits. While Presidential Decree No. 626 has not incorporated the presumption of compensability and the theory of aggravation prevalent under the Workmen's Compensation Act, it continues to be an employees' compensation law or social legislation which should be liberally construed in favor of labor. In Obra vs. Social Security System, the Court reiterated that the Employees Compensation Commission and the Social Security System should adopt a liberal attitude in favor of the employee in deciding claims for compensability, especially where there is some basis in the facts for inferring a work connection with the illness or injury. Article 4 of the New Labor Code provides that all doubts in the implementation and interpretation of the Labor Code, including its implementing rules and regulations, should be resolved in favor of labor. Accordingly, respondent was entitled to death benefits.

• Substantial Evidence and Reasonable Work Connection for Non-Occupational Diseases — Under Presidential Decree No. 626, as amended, and its Implementing Rules, a non-occupational disease is compensable if the claimant proves by substantial evidence that the risk of contracting the disease was increased by the employee's working conditions. The required degree of proof is substantial evidence, or such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The law requires a reasonable work connection, not a direct causal relation; probability, not certainty, is the touchstone. The Court applied this doctrine by finding that Irnido's work in cutting steel materials exposed him to chromium, which studies have linked to a small but significant increase in prostate cancer risk, making a work connection probable.
• Liberal Construction of Presidential Decree No. 626 as Social Legislation — Presidential Decree No. 626, as amended, is an employees' compensation law and 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. Although it has not incorporated the presumption of compensability and the theory of aggravation under the Workmen's Compensation Act, it should be liberally construed in favor of labor. The Social Security System and the Employees Compensation Commission, as implementing agencies, should adopt a liberal attitude in favor of the employee in deciding compensability claims, especially where there is some basis in the facts for inferring a work connection. Article 4 of the New Labor Code requires all doubts in the implementation and interpretation of the Labor Code and its implementing rules to be resolved in favor of labor. The Court relied on this doctrine to affirm the award of death benefits.
• Exceptions to the Rule that Only Questions of Law May Be Raised in a Petition for Review — Factual findings of the Court of Appeals are generally binding and conclusive upon the Supreme Court, especially when supported by substantial evidence, because the Supreme Court is not a trier of facts. However, the rule admits exceptions. Medina vs. Asistio, Jr. laid down the following exceptions: (1) when the conclusion is a finding grounded entirely on speculation, surmises or conjectures; (2) when the inference made is manifestly mistaken, absurd or impossible; (3) where there is a grave abuse of discretion; (4) when the judgment is based on a misapprehension of facts; (5) when the findings of fact are conflicting; (6) when the Court of Appeals, in making its findings, went beyond the issues of the case and the same is contrary to the admissions of both appellant and appellee; (7) when the findings of the Court of Appeals are contrary to those of the trial court; (8) when the findings of fact are conclusions without citation of specific evidence on which they are based; (9) when the facts set forth in the petition as well as in the petitioner's main and reply briefs are not disputed by the respondents; and (10) when the finding of fact of the Court of Appeals is premised on the supposed absence of evidence and is contradicted by the evidence on record. The Court applied the exception of conflicting findings because the Court of Appeals' factual findings differed from those of petitioner and the Employees Compensation Commission.

• "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." — This passage, quoted from Sarmiento vs. Employees' Compensation Commission, states the evidentiary standard for compensability claims under Presidential Decree No. 626 and the controlling reasonable work-connection rule.
• "A review of the records reveals that respondent proved that Irnido's working conditions increased the risk of him contracting prostate cancer." — This is the Court's conclusion on the central compensability issue, applying the substantial evidence standard to the facts of Irnido's steel-cutting work and chromium exposure.
• "It must be stressed that while Presidential Decree No. 626 has not incorporated "the presumption of compensability and the theory of aggravation prevalent under the 'Workmen's Compensation Act[,]'" it continues to be "an employees' compensation law or a social legislation" which should be liberally construed in favor of labor." — This passage defines the legal character of Presidential Decree No. 626 and grounds the liberal construction rule applied in favor of the claimant.
• "Thus, it is not unlikely that Irnido's work increased the risk of him contracting the disease. This probability suffices to warrant the grant of the claimed benefits." — This excerpt states the Court's application of the probability standard to the evidence of chromium exposure from steel cutting, showing why the death benefits were granted.

• Sarmiento vs. Employees' Compensation Commission, 228 Phil. 400 (1986) — Quoted by the Court for the rule that compensation claims require only substantial evidence and a reasonable work connection, not direct causal relation; probability, not certainty, is the touchstone.
• Government Service Insurance System vs. Court of Appeals, 566 Phil. 361 (2008) — Cited by the Court of Appeals in reversing the Employees Compensation Commission; the appellate court relied on it to hold that it was impossible for the claimant to present evidence of causal relation because the specific cause of prostate cancer is medically unknown.
• Government Service Insurance System vs. Palma, 555 Phil. 355 (2007) — Cited for the proposition that Presidential Decree No. 626 has not incorporated the presumption of compensability and the theory of aggravation under the Workmen's Compensation Act, but remains an employees' compensation law or social legislation to be liberally construed in favor of labor.
• Obra vs. Social Security System, 449 Phil. 200 (2003) — Quoted for the rule that the Employees Compensation Commission and the Social Security System should adopt a liberal attitude in favor of the employee in deciding compensability claims, especially where there is some basis for inferring a work connection.
• Medina vs. Asistio, Jr., 269 Phil. 225 (1990) — Cited for the exceptions to the rule that factual findings of the Court of Appeals are binding, including conflicting findings, which allowed the Supreme Court to reevaluate the evidence.
• Pascual vs. Burgos, 776 Phil. 167 (2016) — Cited for the principle that only questions of law should be raised in a petition for review and that factual findings of the Court of Appeals are binding when supported by substantial evidence.

• Labor Code, Title II, Chapter 1, Article 173(1) — 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. Applied to determine that prostate cancer, not being listed, required proof of increased risk.
• Amended Rules on Employees' Compensation (2014), Rule III, Section 1(b) — Provides that for sickness and the resulting disability or death to be compensable, the sickness must be the result of an occupational disease listed under Annex "A"; otherwise, proof must be shown that the risk of contracting the disease is increased by the working conditions. Applied because Irnido's prostate cancer was non-occupational.
• Presidential Decree No. 626, as amended — The governing employees' compensation law; the Court characterized it as a social legislation to be liberally construed in favor of labor.
• Labor Code, Article 4 — Provides that all doubts in the implementation and interpretation of the provisions of the Labor Code, including its implementing rules and regulations, should be resolved in favor of labor. Applied through the Obra quotation to support liberal construction.

Justices Lazaro-Javier, M. Lopez, J. Lopez, and Kho, Jr. concurred.