SSS vs. Simacas GR 217866

Social Security System vs. Violeta A. Simacas

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

Facts:

    Irnido L. Simacas worked as a Fabrication Helper at Fieldstar Manufacturing Corporation from April 1995 until February 2010. Two years before retiring, Irnido complained of back pains and incessant coughing. The said symptoms worsened until he could no longer perform his job and had to retire in February 2010. On 13 July 2010, Irnido died due to Cardiopulmonary Arrest probably secondary to Metastatic Prostatic Adenocarcinoma.

    Irnido's surviving spouse, Violeta Simacas, filed a claim for employee's compensation benefits which was denied by the SSS on the ground that the cause of death was a non-occupational disease. 

    The CA reversed the SSS decision on the basis of PD 626, as amended.

Issue:

1. Whether or not the risk of contracting prostate cancer was increased by Irnido's work conditions; and

2. Whether or not Violeta Simaca is entitled to receive death benefits under PD 626, as amended.

Held: 

1. A review of the records reveals that respondent proved that Irnido's working conditions increased the risk of him contracting prostate cancer.

    Several studies have suggested that work-related exposures to certain substances, such as chromium, have the potential of affecting the risk of getting prostate cancer. A recent study "revealed a small but significant increase in prostate cancer risk for chromium exposure."

    In this case, it is undisputed that the deceased's work included assisting the welder and the machinist is cutting steel materials. It is said that "workers engaged in the manufacturing or handling stainless steel are exposed to chromium in varying degrees."

2. Violeta is entitled to receive death benefits under PD 626.

    Presidential Decree No. 626 continues to be "an employee's compensation law or a social legislation" which should be liberally construed in favor of labor.

        The Court reiterated the ruling in Obra v. SSS which stated that "...as the official agents charged by law to implement social justice guaranteed by the Constitution, the ECC and the SSS 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, as the case may be."

Fulltext: https://sc.judiciary.gov.ph/28593/