FE N. SULIT, Petitioner, v.

EMPLOYEES COMPENSATION COMMISSION and GOVERNMENT

SERVICE INSURANCE SYSTEM (Cavite Naval Shipyard Naval Shore Establishment),Respondents.
FACTS:
Gregorio S. Sulit was employed as a mechanic in the Cavite Naval Shipyard, Naval Shore
Establishment, Cavite Naval Base of the Philippine Navy from May 26, 1966 up to his death on
December 17, 1975 at the age of fifty three years.
Due to persistent backaches and bilateral lumbar pains, accompanied by fever and chills, he was
confined in the Philippine General Hospital from December 11, 1975 up to his death six days later.
He died of acute pyelonephritis and bronchopneumonia.
Fe N. Sulit, the widow of the deceased mechanic, filed a claim for employees compensation under
Presidential Decree No. 626. She contended that her husbands work was postural in nature and
time consuming and that his repairing of a motor vehicle while in a prone position under it for long
perspiring hours daily in the span of his working career produced a kinking of his ureters, thereby
causing a constant and progressive stagnancy of urine flow which led to infection in the urinary tract
and stone formation therein.
ISSUE:
Whether or not death due to Pyelonephritis and Bronchopneumonia is compensable under the
present compensation laws.
LAW:
A compensable sickness "means any illness definitely accepted as an occupational disease listed by
the Employees Compensation Commission, or any illness caused by employment subject to proof
by the employee that the risk of contracting the same is increased by working conditions. For this
purpose, the Commission is empowered to determine and approve occupational diseases and workrelated illnesses that may be considered compensable based on peculiar hazards of employment."
(Art. 167[1], as amended by Presidential Decree No. 1368, effective May 1, 1978.)
RULING:
NO, Pyelonephritis was not caused by her husbands work as a mechanic. The contracting of such a
disease was not increased by the working conditions of his job. Hence, that disease is not
compensable in this case. The same observations apply to bronchopneumonia.

CASE HISTORY:
*GSIS-denied claim
*ECC-denied claim
*CA- compensable
*SC-decisions of the GSIS and the Employees Compensation Commission, denying the claim, are
affirmed. No costs.
OPINION:
Old labor laws are always tilted infavor of the employees and the lawmakers are now taking into
consideration placing the implementation of such into a state of equilibrium, in which the new labor

laws sets enumerations and specific guidelines in which what diseases are compensable so as not
to put the employers at stake.

TERESA M. ARMEA petitioner,

vs.
EMPLOYEES' COMPENSATION COMMISSION AND GOVERNMENT SERVICE INSURANCE
SYSTEM (Municipal Treasurer's Office, Daraga, Albay), respondents.
FACTS:
Patricio D. Armea, husband of the herein petitioner was employed by the government and held the
positions of clerk, public school teacher, budget examiner and lastly as municipal treasurer of
Daraga, Albay, which position he occupied since July 1, 1975 until his death on June 1, 1976. The
cause of his death was certified to be " acute monolytic leukemia."
petitioner filed a claim for employee's compensation with the respondent GSIS which denied the said
claim on the ground that Patricio D. Armea's ailment was not in the least causally related to his
duties and conditions of work, and that there was no showing that said ailment directly resulted from
his occupation or employment as municipal treasurer of Daraga, Albay.
ISSUE:
Whether acute monolytic leukemia is compensable under the present compensation laws.
LAW:
For under P.D. 626, the sickness, to be compensable, must be an occupational disease listed by the
Commission, or if it is not so, then it must be caused by employment and the employee must prove
that the risk of contracting it is increased by working conditions. Nowhere in the law can we find a
provision from which we can draw the presumption that once the illness developed during
employment, it is compensable.
RULING:
NO, In claims grounded on non-occupational disease such as the case at hand, the claimant is
called upon by law to prove that his sickness is caused by his employment and the risk of contracting
it is increased by his working conditions
Moreover, the etiology of "Monolytic Leukemia" from which appellants husband died shows no causal
relation with his work. Leukemia is a generalized proliferative neoplastic disorder of the blood
forming tissues, usually involving the leukecytic series.
The courts have carefully examined the record of the instant case in an effort to find some credible
and adequate basis to show that the acute monolytic leukemia that resulted in the death of the
petitioner's husband could have been caused by or traceable to conditions under which he

Performed his duties as municipal treasurer. Sadly enough Courts efforts proved in vain.
CASE HISTORY:
GSIS-denied claims
ECC-denied claims
CA-denied claims
SC-affirmed CA, denied claims
OPINION:
The doctrine of "presumptive compensability" whereby, when an illness supervened during the
course of employment there is a presumption that the same arose out of or at least was aggravated
in the course of employment as invoked by the petitioner has already been settled in which the state
amended the labor law and takes into consideration the application of such in the state of equilibrium
between employers and employees wherein the old labor law was tilted unduly to the employees and
it is widely abused by them and employers are the one sufferring.