Digest.ph

This case involves a claim for disability benefits under the labor code by Dionisia C. Sante, the wife of Severino T. Sante, who was a driver for the Ministry of Public Works and Highways. Severino Sante suffered from amyotrophic lateral sclerosis (ALS), a degenerative disease that caused muscle weakness and difficulty in breathing and swallowing. The claim was initially denied by the Government Service Insurance System (GSIS) and affirmed by the Employees' Compensation Commission (ECC) on the grounds that ALS was not listed as an occupational disease and that there was no evidence to show that Severino's working conditions had increased the risk of contracting the disease. Severino Sante passed away during the proceedings, and Dionisia Sante continued to pursue the claim. She argued that since the cause of ALS is unknown, there was no duty to prove a causal link between Severino's working conditions and the disease. The main issue in this case is whether Dionisia Sante has a duty to establish a connection between Severino's illness and his working conditions.

The court in this case clarifies that under the current law, the claimant must prove that the illness was caused by the conditions of employment or that the risk of contracting the ailment was increased by such working conditions. However, the court does not require direct evidence of work-causation or work-connection. Instead, the claimant must submit evidence that constitutes a reasonable basis for concluding that the conditions of employment caused the ailment or aggravated the risk of contracting it.