FACTS:

Geronimo Narazo, who worked as a Budget Examiner in the Office of the Governor, Province of Negros Occidental for 38 years, died at the age of 57. His medical records showed that he had been admitted three times to the hospital for various ailments, including urinary retention, abdominal pain, and anemia. The cause of his death was determined to be "Uremia" which was a complication of obstructive nephropathy due to benign prostatic hypertrophy. Narazo's widow filed a claim for death benefits under the Employees' Compensation Law, but it was denied on the grounds that his cause of death was not listed as an occupational disease and there was no evidence that his job as a Budget Examiner increased the risk of contracting the illness. The petitioner argued that her husband's sedentary work, coupled with stress and pressure, led to the development of his ailments. The Employees' Compensation Commission upheld the denial of the claim, stating that the deceased's ailments could not be attributed to employment factors. The petitioner appealed, arguing that the nature and circumstances of her husband's occupation were not considered in determining the risk of contracting the disease.

ISSUES:

1. Whether the death of the petitioner's husband is compensable under PD 626.

2. Whether the risk of contracting the illness was aggravated by the nature of the deceased's work as a Budget Examiner.

RULING:

1. The Court held that the death of the petitioner's husband is compensable and the risk of contracting the illness was aggravated by the nature of the deceased's work. The burden of proof was upon the petitioner to show that the deceased's working conditions had increased the risk of contracting the illness which caused his death. Under the increased risk theory, the claimant must show proof of reasonable work-connection, not necessarily direct causal relation. In this case, the nature of the deceased's work required long sedentary work under pressure, which aggravated the risk of developing the illnesses that led to his death. The Court considered the liberal interpretation of the Labor Code and the social justice guarantee in favor of the workers in making this ruling.

PRINCIPLES:

• Rule III, section 1, paragraph 3(b) of Presidential Decree No. 626, as amended, defines a "compensable sickness" as any illness definitely accepted as an occupational disease listed by the ECC or any illness caused by employment subject to proof by the employee that the risk of contracting the same is increased by working conditions.

• Compensation may still be recovered for a sickness or death caused by an illness that is not listed as an occupational disease if the illness was aggravated by employment.

• To establish compensability under the increased risk theory, the claimant must show proof of reasonable work-connection, not necessarily direct causal relation.

• The degree of proof required for compensability is substantial evidence, which means such relevant evidence as will support a decision or clear and convincing evidence. Strict rules of evidence are not applicable.