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RUBEN T. LIMBO v. EMPLOYEES COMPENSATION COMMISSION

FACTS:

Petitioner Ruben T. Limbo was employed at Nestlé Philippines, Incorporated from November 25, 1966 to December 31, 1996. In December 1994, Limbo was confined at the Philippine General Hospital (PGH) due to joint pains and elevated BUN, creatinine, and anemia. He was diagnosed with chronic renal disease and advised to undergo a kidney transplant. He underwent a renal transplant in January 1995. Limbo filed a claim for compensation benefits before the Social Security System (SSS) under P.D. No. 626, but it was denied. The Employees Compensation Commission (ECC) affirmed the denial. Limbo appealed to the Court of Appeals, but his petition was dismissed. Hence, he filed a petition for review on certiorari before the Supreme Court. The issue is whether "end-stage renal disease secondary to uric acid nephropathy" is compensable under P.D. 626.

ISSUES:

  1. The only issue in this case is whether or not "end-stage renal disease secondary to uric acid nephropathy" is compensable under P.D. 626, as amended.

RULING:

  1. The Supreme Court granted the petition and ruled in favor of the petitioner. They held that even though "end-stage renal disease secondary to uric acid nephropathy" is not listed under Annex "A" of the Amended Rules on Employees Compensation, it can still be compensable if the petitioner can prove that the risk of contracting the disease was increased by his working conditions. The Court found that the workload and areas of responsibility of the petitioner in this case could reasonably lead to the development of hypertension, which in turn led to uremia. The Court also considered the findings of the petitioner's attending physician, who stated that the stress at work could have aggravated his condition. Therefore, the Court ordered the Social Security System to pay the petitioner the compensation benefits due under P.D. 626.

PRINCIPLES:

  • In determining whether a disease is compensable, it is enough that there exists a reasonable work connection. Probability, not certainty, is the touchstone.

  • A physician's report is the best evidence of the work-connection of workmen's ailments and can be the basis of an award, even if the physician was not presented as a witness.