In Government Service Insurance System (GSIS) vs. Maria Teresa S.A. Cordero, the Supreme Court affirmed that an employee’s illness, even if not listed as an occupational disease, is compensable if the employee can prove that their working conditions increased the risk of contracting the illness. Maria Teresa Cordero successfully demonstrated that her hypertension, stemming from her work at GSIS, led to Chronic Glomerulonephritis and ultimately End Stage Renal Disease, entitling her to compensation benefits under Presidential Decree No. 626. This decision emphasizes the importance of considering the totality of an employee’s working conditions when assessing claims for work-related illnesses, especially when those illnesses are connected to pre-existing conditions exacerbated by work.

When a Healthy Start Leads to a Compensable Kidney Disease: The Cordero Case

The case revolves around Maria Teresa S.A. Cordero, a long-time employee of the Government Service Insurance System (GSIS). Starting in 1987, Cordero held various positions before securing a permanent appointment in 1990, and later a promotion to Senior General Insurance Specialist in 1996. Her work involved examining insured government properties, assessing risks, inspecting damages, and determining GSIS’s liability for insurance claims. Crucially, Cordero’s pre-employment medical examinations showed she was in perfect health when she joined GSIS. However, in 1995, she was diagnosed with hypertension, and subsequently, in 2000 and 2001, she was hospitalized and diagnosed with Chronic Renal Failure secondary to Chronic Glomerulonephritis. This led her to file a claim for compensation benefits under P.D. No. 626, arguing that her illness was work-related.

The GSIS initially denied Cordero’s claim, arguing that her illness was not work-connected and that her duties did not increase the risk of contracting it. This denial was upheld by the Employees’ Compensation Commission (ECC), which stated that there was no proof she was significantly exposed to occupational hazards that would result in kidney injury. Cordero then appealed to the Court of Appeals, which reversed the ECC’s decision. The Court of Appeals found that Cordero contracted Chronic Glomerulonephritis during her employment at GSIS and that her working conditions increased the risk of contracting the disease. This ruling was based on the fact that she was in perfect health during her pre-employment examination but later developed hypertension, which led to her kidney disease. The GSIS and ECC then filed separate petitions for review on certiorari, leading to the Supreme Court’s decision.

The central legal question was whether Cordero’s End Stage Renal Disease, secondary to Chronic Glomerulonephritis, was compensable under P.D. No. 626, as amended. The GSIS argued that Chronic Glomerulonephritis is not an occupational disease and that Cordero failed to prove that her working conditions increased the risk of contracting it. Cordero, on the other hand, contended that her working conditions did increase the risk of contracting the illness, as evidenced by her initial good health and subsequent development of hypertension due to the strenuous nature of her work. The Supreme Court ultimately sided with Cordero, affirming the Court of Appeals’ decision.

The Supreme Court based its decision on Section 1(b) of Rule III implementing P.D. No. 626, which states that sickness is compensable if it is an occupational disease or if the risk of contracting the disease is increased by the working conditions. The Court noted that strict rules of evidence are not applicable in these cases, and the quantum of evidence required is merely substantial evidence. Substantial evidence is defined as “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” The Court emphasized that a reasonable work-connection, rather than a direct causal relation, is sufficient for compensability. The hypothesis on which the claim is based need only be probable, as probability, not certainty, is the touchstone.

In this case, Cordero’s disease was not listed as an occupational disease, so she had to provide substantial proof that the nature of her employment or working conditions increased the risk of End Stage Renal Disease or Chronic Glomerulonephritis. The evidence presented by Cordero indicated that her Chronic Glomerulonephritis, which led to End Stage Renal Disease, was caused by hypertension. The Court highlighted that Cordero was given a clean bill of health when she was employed by GSIS in 1987, but she contracted hypertension in 1995. Although End Stage Renal Disease is not listed as an occupational disease, it is scientifically linked to hypertension, a compensable illness.

The Supreme Court gave weight to the certification from Cordero’s attending physician, which stated that her hypertension had led to the development of her End Stage Renal Disease. The Court acknowledged that a doctor’s certification as to the nature of a claimant’s disability typically deserves full credence. The court said that, in general, no medical practitioner would issue certifications indiscriminately, given the serious implications of false certifications on their professional interests. Here, the court cites Ijares v. Court of Appeals, G.R. No. 105854, August 26, 1999, 313 SCRA 141, 151-152:

In our jurisprudence, a doctor’s certification as to the nature of the claimant’s disability normally deserves full credence because in the normal course of things, no medical practitioner will issue certifications indiscriminately, considering the serious and far-reaching effects of false certifications and its implications upon his own interests as a professional.

The Court also considered the Certification issued by Mr. Arnulfo Q. Canivel, Division Chief III, GSIS Claims Department, which stated that Cordero’s work and working conditions outside the office increased the risk and were probably a big factor in the development of her hypertension, which led to her End Stage Renal Disease. The Supreme Court stated that they cannot close their eyes to the reasonable connection of her work vis-à-vis her ailment. By proving that she was healthy upon entry to GSIS, that her working conditions caused her hypertension, and that her hypertension led to Chronic Glomerulonephritis and End Stage Renal Disease, Cordero was able to demonstrate the necessary link between her work and her illness.

Ultimately, the Supreme Court’s decision underscores the importance of considering the totality of an employee’s circumstances when evaluating claims for work-related illnesses. This case reinforces the principle that social legislation like P.D. No. 626 should be interpreted liberally in favor of its intended beneficiaries. This aligns with jurisprudence such as Salalima v. Employees’ Compensation Commission, G.R. No. 146360, May 20, 2004, 428 SCRA 715, 723 stating:

What the law requires is a reasonable work-connection and not a direct causal relation.

In cases where an illness is not specifically listed as an occupational disease, employees can still successfully claim compensation by providing substantial evidence that their working conditions increased the risk of contracting the illness. This evidence may include pre-employment health records, medical certifications linking the illness to a pre-existing condition, and documentation showing the nature of the employee’s work and working conditions.

FAQs

What was the key issue in this case?	The key issue was whether Maria Teresa Cordero’s End Stage Renal Disease, secondary to Chronic Glomerulonephritis, was compensable under P.D. No. 626, as amended, given that it is not a listed occupational disease. The court had to determine if her working conditions increased the risk of contracting the illness.
What is Presidential Decree No. 626?	Presidential Decree No. 626 is a law that provides for compensation benefits to employees who suffer work-related injuries, illnesses, or death. It aims to provide a system of compensation for employees who are unable to work due to work-related causes.
What does “substantial evidence” mean in this context?	Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. It is a lower standard of proof than “preponderance of evidence” or “proof beyond a reasonable doubt”.
How did the Court of Appeals rule in this case?	The Court of Appeals reversed the ECC’s decision and ruled in favor of Maria Teresa Cordero, finding that her working conditions increased the risk of contracting Chronic Glomerulonephritis. They directed the GSIS to pay her claim for compensation benefits.
What was GSIS’s main argument against the compensation claim?	GSIS argued that Chronic Glomerulonephritis is not an occupational disease and that Cordero failed to prove that her working conditions increased the risk of contracting the disease. Therefore, they believed her illness was not compensable under the law.
Why was the physician’s certification important in this case?	The physician’s certification was important because it linked Cordero’s hypertension, which developed during her employment, to the development of her End Stage Renal Disease. The court gave credence to the certification because it is assumed that medical practitioners do not issue certifications indiscriminately.
What is the significance of a pre-employment medical examination?	A pre-employment medical examination establishes a baseline of an employee’s health condition upon entering employment. In this case, it was significant because it showed that Cordero was in perfect health when she joined GSIS, suggesting that her subsequent health issues were related to her work.
What is the “increased risk” theory in compensation cases?	The “increased risk” theory states that even if an illness is not directly caused by work, it is compensable if the employee’s working conditions significantly increased the risk of contracting the illness. This theory is particularly relevant when an employee has a pre-existing condition that is aggravated by their work environment.

The Supreme Court’s decision in GSIS vs. Cordero serves as a reminder of the importance of protecting employees’ rights to compensation for work-related illnesses. It underscores the principle that social legislation should be interpreted in favor of its intended beneficiaries. It is the responsibility of employers and the GSIS to properly assess claims of employee ailments, especially when considering what amounts to substantial proof as set by jurisprudence.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS) VS. MARIA TERESA S.A. CORDERO, G.R. NO. 171378, March 17, 2009