CASE DIGEST: Corporal v. Employees' Compensation Commission

 


RAMON CORPORAL, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and GOVERNMENT SERVICE INSURANCE SYSTEM, respondents
G.R. No. 86020                  |              August 5, 1994

FACTS:

Norma Peralta Corporal was a public school teacher at Banadero Elementary School in Daraga, Albay. Norma had to walk 3 kilometers to and from said school to the national highway as no transportation was available to ferry her and other teachers. During her fourth pregnancy, Norma suffered a complete abortion and was hospitalized for two days at the Albay Provincial Hospital.

On March 1984, she again conceived. However, on September, she was transferred to the Kilicao Elementary School, where she had to walk more than one kilometer of rough road.

On December 2, 1984, she gave birth to a baby boy and had a profuse vaginal bleeding and she later died due to “shock, severe haemorrhage” resulting from “prolapsed uterus post partum.”

When her husband, Ramon Corporal, filed a claim for compensation benefit with the GSIS, GSIS denied petitioner’s claim, on the basis that her cause of death is “non-work-connected as contemplated under the law” and neither did her job as a teacher increase the risk of contracting her ailment.

Petitioner appealed to the ECC, which also later denied petitioner’s claim. It explained that the development of the fatal illness has no relation whatsoever with the duties and working conditions of the late teacher and that there is no showing that the nature of her duties caused the development of prolapse of the uterus. The ailment was a complication of childbirth causing profuse vaginal bleeding during the late stage.

Petitioner contends that although prolapsed uterus is not one of the occupational diseases listed by the ECC, his claim should prosper under the increased risk theory. He anchors such claim on the fact that as early as January 1984 or before Norma’s fifth pregnancy, he had noticed a spherical tissue which appeared like a tomato protruding out of Norma’s vagina and rectum, which he claims to be attributable to Norma’s long walks to and from her place of teaching.

ISSUE:

Whether or not Norma’s death is compensable

RULING:

The fact that Norma had to walk six kilometers everyday and thereafter, a shorter distance of more than one kilometer just to reach her place of work, was not sufficient to establish that such condition caused her to develop prolapse of the uterus. Petitioner did not even present medical findings on the veracity of his claim that Norma had a tomato-like spherical tissue protruding from her vagina and rectum.

Norma developed prolapse of the uterus because she was multiparas, or one who had more than one child, and quite beyond the safe child-bearing age when she gave birth to her fifth child.

The determination of whether the prolapse of Norma’s uterus developed before or after her fifth pregnancy is therefore immaterial since this illness is the result of the physiological structure and changes in the body on pregnancy and childbirth.


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