Manahan vs. Employees' Compensation Commission

The law governing a claim for workmen's compensation is the law in force at the time the cause of action accrued, not at the time of death or filing of the claim. Where the cause of action accrues prior to the effectivity of the Labor Code — specifically during the period from November 1, 1974 to December 31, 1974 — the claim shall be processed and adjudicated under the Workmen's Compensation Act, which carries a statutory presumption of compensability in favor of the worker. Further, in case of doubt, social legislation must be liberally construed to afford relief to the workman and his dependents.

Nazario Manahan, Jr. entered government service on July 20, 1969, in perfect health. He was employed as a classroom teacher at Las Piñas Municipal High School in Las Piñas, Rizal. As part of his daily routine, he ate his meals at the school canteen and used the toilet and other facilities of the school premises. On December 10, 1974, he was treated for epigastric pain, symptoms that were consistent with the onset of enteric fever. He died of enteric fever on May 8, 1975. His widow, Maria E. Manahan, filed a claim for death benefits.

• The Deceased and His Employment: Nazario Manahan, Jr. was a classroom teacher at Las Piñas Municipal High School in Las Piñas, Rizal. He entered government service on July 20, 1969, in perfect health. In the course of his employment, he regularly ate his meals at the school canteen and used the toilet and other facilities of the school.

• Onset of Illness and Medical Treatment: The medical record and a certificate issued by Dr. Aquilles Bernabe established that Nazario Manahan, Jr. was treated for epigastric pain, probably due to hyperacidity, on December 10, 1974. Epigastric pain is a symptom of ulcer, and ulcer is a common complication of typhoid fever. The lingering nature of the salmonella organism producing enteric fever indicated that the illness which afflicted the deceased as early as 1974 was the same as, or at least related to, the illness that caused his death in 1975.

• Death and Claim for Benefits: Nazario Manahan, Jr. died of enteric fever on May 8, 1975. His widow, petitioner Maria E. Manahan, filed a claim for death benefits under Presidential Decree 626 with the Government Service Insurance System.

• Nature of Enteric Fever: Enteric fever is medically synonymous with typhoid fever or paratyphoid fever. It is caused by salmonella organisms acquired through ingestion of contaminated food or drinks. Contamination may originate from the excretion of rodents, flies, or human carriers, or from infection in meat, milk, and eggs — foods most frequently involved in transmission because the organism may multiply even before ingestion.

• Findings of the Employees' Compensation Commission: The ECC itself found that it was "not improbable that the deceased might have contracted the illness during those rare moments that he was away from his family," given that his working conditions involved eating meals at the school canteen, which exposed him to food and water that could be contaminated.

• Compensability: Petitioner argued that the deceased was in perfect health when admitted to government service and that his ailment, enteric fever, was attributable to his employment as a classroom teacher. She relied on medical authority establishing that enteric fever is transmitted through ingestion of contaminated food or water — precisely the kind of exposure the deceased faced when eating at the school canteen.

• Relevance of Prior Medical Treatment: Petitioner maintained that the deceased's treatment for epigastric pain on December 10, 1974, demonstrated an illness related to the enteric fever that later claimed his life, pointing to an earlier onset and a cause of action accruing before the Labor Code's full effectivity.

• Non-Occupational Nature of the Disease: The GSIS denied the claim on the ground that typhoid fever (enteric fever) is not an occupational disease. On reconsideration, it maintained that enteric fever or paratyphoid is similar in effect to typhoid fever, both being produced by salmonella organisms and not among the diseases recognized as occupational.

• No Causal Link to Employment: The Employees' Compensation Commission found that enteric fever was not induced by or aggravated by the nature of the duties of Nazario Manahan, Jr. as a classroom teacher, implying that the teaching profession did not inherently expose him to the risk of contracting the illness.

• Applicable Law: Whether Presidential Decree 626 (the Labor Code) or the Workmen's Compensation Act, as amended, governed the adjudication of the petitioner's claim for death benefits.

• Compensability: Whether the death of Nazario Manahan, Jr. from enteric fever was compensable under the governing law.

• Applicable Law: The claim was adjudicated under the Workmen's Compensation Act, as amended, not the Labor Code. Pursuant to the controlling precedent in Corales v. ECI, Article 294 of the Transitory and Final Provisions of the New Labor Code provides that all actions and claims accruing prior to the effectivity of the Code shall be determined in accordance with the law in force at the time of their accrual. Further, under the third paragraph of Article 292 on Prescription of Offenses and Claims, workmen's compensation claims accruing prior to the effectivity of the Code and during the period from November 1, 1974 up to December 31, 1974 shall be processed and adjudicated in accordance with the law and rules at the time their causes of action accrued. The medical records showed that the deceased had been treated for epigastric pain on December 10, 1974, and that the illness that claimed his life could have had its onset months before that date. His cause of action therefore accrued before December 10, 1974, effectively before the Labor Code's effectivity on November 1, 1974.

• Compensability: Under the Workmen's Compensation Act, the presumption of compensability subsisted in favor of the claimant. The ECC's own findings established that the risk of contracting enteric fever was increased by the deceased's working conditions: as a teacher who ate meals at the school canteen and used the school's toilet facilities, he was exposed to food and water that could be contaminated by salmonella organisms — the very transmission mechanism for enteric fever. The constitutional guarantee of social justice and protection to labor mandated a liberal construction of social legislation to attain its objective of giving relief to the workman and his dependents. Any doubt must be resolved in favor of the worker.

• Doctrine of Accrual Governing Applicable Law for Workmen's Compensation Claims — The law in force at the time the cause of action accrues, not the law at the time of death or filing of claim, determines the legal framework for adjudicating workmen's compensation claims. Under Article 294 of the Transitory and Final Provisions of the New Labor Code, all actions and claims accruing prior to the effectivity of the Code shall be determined under the laws in force at the time of their accrual. Under the third paragraph of Article 292, claims accruing during the period from November 1, 1974 up to December 31, 1974 shall be processed and adjudicated in accordance with the law and rules at the time their causes of action accrued. Here, since the cause of action accrued before December 10, 1974, the Workmen's Compensation Act applied, carrying with it the presumption of compensability.

• Presumption of Compensability under the Workmen's Compensation Act — Under the Workmen's Compensation Act, a statutory presumption exists in favor of the claimant that the illness or injury arose out of or in the course of employment. Once the claimant shows that the illness occurred during the employment, the burden shifts to the employer or the system to rebut this presumption. This presumption was applied in favor of the petitioner once the Court determined the applicable law.

• Doctrine of Increased Risk — Even where a disease is not listed as occupational, compensability may be established by showing that the risk of contracting the illness was increased by the working conditions. The ECC's own factual findings that the deceased ate at the school canteen and used school toilet facilities — conditions under which enteric fever could be transmitted — established the nexus between employment and illness.

• Liberal Construction of Social Legislation — Social legislation, including the Workmen's Compensation Act and the Labor Code, shall be liberally construed to attain their laudable objective of giving relief to the workman and his dependents in the event the former should die or sustain an injury. In case of doubt, the doubt shall be resolved in favor of the worker.

• "In case of doubt, the same should be resolved in favor of the worker, and that social legislations – like the Workmen's Compensation Act and the Labor Code – should be liberally construed to attain their laudable objective, i.e., to give relief to the workman and/or his dependents in the event that the former should die or sustain an injury."

• "These findings of the respondent Commission lead to the conclusion that the risk of contracting the fatal illness was increased by the decedent's working condition."

• "The lingering nature of the species producing enteric fever points out the possibility that the illness which afflicted the deceased in 1974 was the same as, or at least, related to, his 1975 illness."

• Corales v. ECI, G.R. No. L-44063, February 27, 1979 — This case provided the controlling doctrine that workmen's compensation claims accruing prior to the effectivity of the Labor Code shall be determined under the Workmen's Compensation Act. The Court relied squarely on this precedent to hold that the petitioner's claim fell under the older statute, thereby triggering the presumption of compensability.

• Article 294, Title III (Transitory and Final Provisions), New Labor Code — Mandates that all actions and claims accruing prior to the effectivity of the Labor Code shall be determined in accordance with the laws in force at the time of their accrual. Applied to shift the governing law from the Labor Code to the Workmen's Compensation Act because the cause of action accrued before the Code took effect.

• Article 292, third paragraph (Prescription of Offenses and Claims), New Labor Code — Provides that workmen's compensation claims accruing prior to the effectivity of the Code and during the period from November 1, 1974 up to December 31, 1974 shall be processed and adjudicated in accordance with the laws and rules at the time their causes of action accrued. Applied to confirm that the specific transitional period covered the petitioner's claim.

• Workmen's Compensation Act, as amended — Applied as the substantive law governing the claim, including its presumption of compensability in favor of the worker.

• Chief Justice Teehankee (Chairman), Justice Makasiar, Justice Guerrero, and Justice De Castro concurred in the majority opinion.
• Justice Melencio-Herrera concurred in a separate opinion, emphasizing that although enteric fever is not an occupational disease, the risk of contracting it could have been increased by the working conditions of the deceased, a teacher who used to eat his meals at the school canteen and used the comfort room and other facilities of the school.