Case Digest: Limbo vs. ECC and SSS

Limbo vs. ECC and SSS, July 30, 2002 G.R. No.146891

Facts:

Ruben Limbo was employed at Nestlé Philippines, Incorporated as salesman in 1966 and was later promoted as Area Sales Supervisor in 1977 until 1996. In 1994, he was diagnosed with elevetaed BUN, creatinine, anemia and chronic renal disease. In 1995, he underwent a renal transplant. Limbo claimed for benefits from SSS bu the latter denied the claim, reasoning that Limbo’s illness, “end-stage renal disease secondary to uric acid nephropathy,” had no causal relationship to his job as Area Sales Supervisor. The ECC and CA dismissed the appeal.

Issue: Whether or not “end-stage renal disease secondary to uric acid nephropathy” is compensable under P.D. 626

Ruling:

The Court held that petitioner was able to show that his ailment was work-related and was, thus compensable.

Generally, for the sickness and the resulting disability to be compensable, it must be among the listed occupational diseases under the Amended Rules on Employees compensation. But the list is not exclusive and ailments not enumerated therein may still be compensable if claimant could prove that the risk of contracting the illness was increased by his working conditions or that there exist a “reasonable work connection”. The Court upheld the physician’s report which certified that Limbo’s illness was aggravated by the nature of his work. The ailment, being work-connected, was compensable.

Categories: 2002 G.R. No.146891, compensability, July 30, LABOR LAW, Labor Standards, Limbo vs. ECC and SSS, occupational diseases