Domna N.

Villavert, petitioner, v Employees’ Compensation Commission & Government

Service Insurance System (Philippine Constabulary), respondents. G.R No. L-48605, December
14, 1981.
Statement of issue/s: Marcelino N. Villavert the son of the petitioner and employee of the
Philippine Constabulary, died of hemorrhagic pancreatitis On December 12, 1975. The petitioner
filed a claim of income benefits on the death of her son under P.D. No. 626 as amended with the
Government Service Insurance System (GSIS) on March 18, 1976. The said claim was denied by
GSIS on the ground and issue that arises that hemorrhagic pancreatitis is not an occupational
disease, and the petitioner failed to prove that there was a casual connection of the fatal ailment
of Marcelino and his nature of work.
Petitioner’s argument/s: The petitioner appealed to the Employees' Compensation Commission
which affirmed on May 31, 1978 the decision of the respondent, Government Service Insurance
System, denying the claim.
Respondent’s argument/s: The Government Service Insurance System and the Employees'
Compensation Commission denied the claim for compensation on the ground that the petitioner
did not present evidence that the illness of Marcelino N. Villavert, acute hemorrhagic
pancreatitis, was caused or aggravated by the nature of his duties as employee of the Philippine
Constabulary.
Lecture learn: Under Article 4 of the Labor Code of the Philippines, as amended, provides that
"All doubts in the implementation and interpretation of this Code, including its implementing
rules and regulations shall be resolved in favor of labor." And since it was established that
Marcelino handled administrative function, computer operations and typing jobs on the day of
his death, a connection of his occupation to his cause of death becomes visible, does Article 4
favors him,
Decision: The Employees' Compensation Commission, citing a book on medicine, said: In
medical science, acute hemorrhagic pancreatitis is "acute inflammation with hemorrhagic
necrosis of the pancreas." It occurs most commonly in association with alcoholism. The onset of
the symptoms often occurs during or shortly after bouts of alcoholic intoxication. It also occurs
in association with biliary tract disease. Occasionally, it occurs as a complication of peptic ulcer,
mumps, viral hepatitis or following the use of drugs such as glucocorticoids, or chlorothiazide. It
is sometimes associated with metabolic disorders such as hyperpidemia and
hyperparathyroidism. It may also be associated with a genetic type of pancreatitis with onset in
childhood. Trauma is a relatively frequent cause of pancreatitis; it may result from a severe blow
to the abdomen, a penetrating injury from a bullet or knife wound, inadvertent trauma from
surgical procedures in the upper abdomen or rarely, electric shock. Approximately 20% of the
patients have no apparent underlying or predisposing cause. (Principles of Internal Medicine by
Harrison, 7th Edition, pp. 157). However, the Medico Legal Officer of the National Bureau of
Investigation stated that the exact cause of acute hemorrhagic pancreatitis is still unknown
despite extensive researches in this field, although most research data are agreed that physical
and mental stresses are strong causal factors in the development of the disease. From the
foregoing facts of record, it is clear that Marcelino N. Villavert died of acute hemorrhagic
pancreatitis which was directly caused or at least aggravated by the duties he performed as coder
verifier, computer operator and clerk typist of the Philippine Constabulary. There is no evidence
at all that Marcelino N. Villavert had a "bout of alcoholic intoxication" shortly before he died.
Neither is there a showing that he used drugs. It should be noted that Article 4 of the Labor
Code of the Philippines, as amended, provides that "All doubts in the implementation and
interpretation of this Code, including its implementing rules and regulations shall be resolved in
favor of labor." Wherefore, the decision of the Employees' Compensation Commission sought to
be reviewed is set aside and judgment is hereby rendered ordering the Government Service
Insurance System to pay the petitioner death benefits in the amount of SIX THOUSAND PESOS
(P6,000.00). So, ordered.
Ratio: Respondents concluded their decision, based on one research alone without considering
Artcle 4 of the Labor Code, while the medico legal of the NBI, stated that the cause of death of
Marcelino as none occupational is not yet proven, which ultimately gives the Court the reason to
render its judegment.