GLORIA D. MENEZ VS.

ECC
G.R. L-48488, April 25, 1980

Facts:

Petitioner Gloria D. Menez was employed by the Department of Education & Culture as a
schoolteacher. She retired in 1975 under the disability retirement plan at the age of 54 years after 32
years of teaching, due to rheumatoid arthritis and pneumonitis. Before her retirement, she was assigned
at Raja Soliman High School in Tondo-Binondo, Manila near a dirty creek.

Petitioner filed a claim for disability benefits under Presidential Decree No. 626, as amended,
with respondent Government Service Insurance System. On October 25, 1976, respondent GSIS denied
said claim on the ground that petitioner’s ailments, rheumatoid arthritis and pneumonitis, are not
occupational diseases taking into consideration the nature of her particular work.

Issue:

Whether or not the petitioner’s ailments are causally related to her duties and conditions of
work, hence, she is entitled to disability benefit from the GSIS.

Ruling:

Republic Act 4670, otherwise known as the Magna Charta for Public School Teachers, recognized
the enervating effects of these factors (duties and activities of a school teacher certainly involve
physical, mental and emotional stresses) on the health of school teachers when it directed in one of its
provisions that "Teachers shall be protected against the consequences of employment injury in
accordance with existing laws. The effects of the physical and nervous strain on the teachers' health
shall be recognized as compensable occupational diseases in accordance with laws"
 CLEMENTE vs GSIS
G.R. No. L-47521, July 31, 1987

Facts:

Petitioner's husband, the late Pedro Clemente, was for ten (10) years a janitor in the
Department of Health assigned at the Ilocos Norte Skin Clinic. He was hospitalized due to his ailment of
"nephritis," and also found to be suffering from such ailments as portal cirrhosis and leprosy, otherwise
known as Hansen's Disease. Pedro Clemente died of uremia due to nephritis. Thereafter, petitioner filed
with the GSIS a claim for employees' compensation under the Labor Code, as amended. The GSIS denied
the claim of the petitioner because the ailments of her husband are not occupational diseases. The
petitioner requested for reconsideration of the GSIS' denial of her claim, stating that the ailments of her
husband were contracted in the course of employment and were aggravated by the nature of his work.

GSIS together with ECC ruled the deceased's ailments are not listed as occupational diseases,
appellant failed to prove that such ailments were caused by deceased's employment and that the risk of
contracting the same was increased by his working conditions in order to be compensable. Hence, this
petition for review assailing the decision of GSIS.

Issue:

Whether or not the ailments of Pedro Clemente were contracted in the course of employment
and entitled to claim compensation.

Ruling:

YES. The Supreme Court ruled that strict rules of evidence are not applicable in claims for
compensation. What the law requires is a reasonable work-connection and not a direct causal relation.
The major ailments of the deceased, i.e. nephritis, leprosy, etc., could be traced from bacterial and viral
infections. In the case of leprosy, it is known that the source of infection is the discharge from lesions of
persons with active cases. It is believed that the bacillus enters the body through the skin or through the
mucous membrane of the nose and throat. The husband of the petitioner worked in a skin clinic. As
janitor of the Ilocos Norte Skin Clinic, Mr. Clemente was exposed to different carriers of viral and
bacterial diseases. He had to clean the clinic itself where patients with different illnesses come and go.
He had to put in order the hospital equipments that had been used. He had to dispose of garbage and
wastes that accumulated in the course of each working day. He was the employee most exposed to the
dangerous concentration of infected materials, and not being a medical practitioner, least likely to know
how to avoid infection. It is, therefore, not unreasonable to conclude that Mr. Clemente's working
conditions definitely increased the risk of his contracting the aforementioned ailments. This Court has
held in appropriate cases that the conservative posture of the respondents is not consistent with the
liberal interpretation of the Labor Code and the social justice guarantee embodied in the Constitution in
favor of the workers. The SC ordered respondent to pay the petitioner death benefits.
 NICANOR CERIOLA v. NAESS SHIPPING PHILIPPINES
GR No. 193101, Apr 20, 2015

Facts:
 SOCIAL SECURITY COMMISSION v. EDNA A. AZOTE
GR No. 209741, April 15, 2015

Facts:

Edgardo submitted Form E-4 to Social Security System (SSS) with Edna and their 3 older children
as designated beneficiaries. Later in 2001, he submitted another Form E-4 designating their 3 younger
children as additional beneficiaries. When Edgardo died, Edna filed her claim for death benefits with the
SSS as the wife of a deceased-member. However, SSS records showed the Edgardo had submitted
another Form E-4 in 1982 with a different set of beneficiaries, namely: Rosemarie Azote, as spouse, and
Elmer Azote, as dependent. Consequently, Edna's claim was denied, but her 6 children were adjudged as
beneficiaries.
Edna filed a petition with the SSC to claim benefits, insisting she was the legitimate wife. SSC
dismissed Edna's petition because Edgardo did not revoke the previous designation of Rosemarie as
wife-beneficiary, and Rosemarie was still presumed to be the legal wife. SSC also noted that the NSO
records revealed the marriage of Edgardo and Rosemarie was registered in 1982. Hence, Edgardo's
marriage with Edna was not valid as there was no showing that his 1st marriage had been annulled or
dissolved.
On appeal, the CA reversed and set aside the resolution & order of the SSC and held that the SSC
could not make a determination of the validity of the marriage of Edna to Edgardo. Thus, the present
petition for review on certiorari on the assailed CA decision.

Issue:

Whether Edna Azote is entitled to the SSS death benefits as the wife of a deceased member.

Ruling:

NO. Edna cannot be the beneficiary because she is not considered the legal spouse of Edgardo
as their marriage took place during the existence of a previously contracted marriage. The law in force at
the time of Edgardo's death was RA 8282. Sec 8 (e) and (k) expressly provide that it is the legal spouse
who would be entitled to receive benefits rom an SSS deceased member.

In this case, there is concrete proof (NSO certification) of Edgardo's earlier contracted marriage
with Rosemarie, making her the first and legal wife. At the time of the celebration of the 2nd marriage of
Edgardo with Edna, the Family Code was already in force. Article 41 states "a marriage contracted by any
person during the subsistence of a previous marriage shall be null and void..." In claiming benefits, the
settled rule from Signey v. SSS is that "whoever claims entitlement benefits provided by law should
establish his or her right by substantial evidence". Edna failed to establish that there was no impediment
at the time of the celebration of their marriage.

Lastly, although the SSC is not intrinsically empowered to determine the validity of marriages, it
is required by Sec 4(b)(7) of RA 8282 to examine available statistical and economic data to ensure that
the benefits fall into the rightful beneficiaries. In the case, SSC's denial of Edna's claim is correct as it
determined Edna's eligibility based on available statistical data and database documents.
 SOCIAL SECURITY COMMISSION v. AGUAS
G.R. No. 165546, February 27, 2006

Facts:

Pablo Aguas, a member of the Social Security System (SSS) and a pensioner died. Pablo’s
surviving spouse, Rosanna, filed a claim With the SSS for death benefits. However, Pablo’s sister
contested Rosanna’s claim alleging that Rosanna abandoned the family abode more than six years
before Pablo’s death and lived with another man, Romeo. She also presented a marriage certificate
between Romeo and Rosanna. As a result, the SSS suspended the payment of Rosanna and Jeylnns’
monthly pension. SSS denied Rosanna’s request to resume the payment of their pensions. She was
advised to refund to the SSS within 30days days the amount of the total death benefits released to her
and Jeylnn.

The SSC ruled that Rosanna was longer qualified as primary beneficiary as it appeared that she
had contracted marriage to another man during the subsistence of her marriage to Pablo. The SSC
concluded that Rosanna has no longer entitled to support from Pablo prior to his death because of her
act of adultery. As for Jeylnn, the SSC ruled that, even if her birth certificate was signed by Pablo as her
father, there was more compelling evidence that Jeylnn was not his legitimate child. The SSC deduced
from the records that Jeylnn was the daughter of Rosanna and Romeo.

On appeal, the CA reversed the decision of the SSS. The CA relied on the birth certificate of
Jeylnn showing that she was the child of the deceased. According to the appellate court, for judicial
purposes, this record was binding upon the parties, including the SSS. The entries made in public
documents may only be challenged through adversarial proceedings in courts of law and may not be
altered by mere testimonies of witnesses to the contrary. As for Rosanna, the CA found no evidence to
show that she ceased to receive support from Pablo before he died. Rosanna"s alleged affair with
Romeo was not properly proven. In any case, even if Rosanna married Romeo during her marriage to
Pablo, the same would have been a void marriage, it would not have ipso facto made her not dependent
for support upon Pablo and negate the presumption that, as the surviving spouse, she is entitled to
support from her husband. Hence , this petition.

Issue:

Whether or not Rosanna and jeylnn are entitled to the SSS death benefits accruing from the
death of Pablo.

Ruling:

Only the child, Jeylnn, is entitled to the SSS death benefits accruing from the death of Pablo.
Jeylnn’s claim is Justified by the photocopy of her birth certificate which bears the signature of Pablo.
Petitioner has able to authenticate the certification from the Civil Registry. The records also show that
Rosanna and Pablo were legally married, and the marriage subsisted until the latter’s death. It is
therefore evident that Jeylnn was born during Rosanna and Pablo’s marriage. It bears stressing that
under Article 164 of the Family Code, children conceived or born during the marriage of the parents are
legitimate.
 On the claims of Rosanna, it bears stressing that for her to qualify as a primary beneficiary, she
must prove that she was the legitimate spouse dependent for support from the employee. The claimant
spouse must therefore establish two qualifying factors: (1) that she is the legitimate spouse, and (2) that
she is dependent upon the member for support. In this case, Rosanna has not sufficiently established
that she was still dependent on Pablo at the time of his death. indeed, a husband and wife are obliged to
support each other, but whether one is actually dependent from support upon the other is something
that has to be shown; it cannot be presumed from the fact of marriage alone.

The obvious conclusion then is that a wife is already separated de facto from her husband
cannot be said to be “dependent for support” upon the husband, absent any showing to the contrary.
Conversely, if it is proved that the husband and wife were still living together at the time of his death, it
would be safe to presume that she has dependent on the husband for support, unless it is shown that
she is capable of providing for herself. Thus, since Rossana failed to prove that she was still for support
upon Pablo at the time of his death even if they were living separately, likewise was disqualified as
primary beneficiary of SSS benefits.