otherwise complex fact-finding process that should have taken place to determine
the true cause of the ailment.
In Sante v. Employees Compensation Commission,[21] this Court ruled that "
a claimant must submit such proof as would constitute a reasonable basis for
concluding either that the conditions of employment of the claimant caused the
ailment or that such working conditions had aggravated the risk of contracting that
ailment. What kind and quantum of evidence would constitute an adequate basis
for a reasonable man (not necessarily a medical scientist) to reach one or the other
conclusion, can obviously be determined only on a case-to-case basis. That
evidence must, however, be real and substantial, and not merely apparent; for the
duty to prove work-causation or work-aggravation imposed by existing law is real
not merely apparent."
Moreover, petitioner cannot conveniently rely on the invocation that the
Employees Compensation Act, as a social legislation, must be liberally construed
in favor of the ordinary working person. While the sympathy of the law on social
security is toward the employees or their beneficiaries, it is imperative to
remember that such compassion must be balanced by the equally vital interest of
denying undeserving claims for compensation benefits. Thus, GSIS v. CA[22] held:
x x x [T]here is a competing, yet equally vital interest to heed in passing
upon undeserving claims for compensation. It is well to remember that if diseases
not intended by the law to be compensated are inadvertently or recklessly
included, the integrity of the State Insurance Fund is endangered. Compassion for
the victims of diseases not covered by the law ignores the need to show a greater
concern for the trust fund to which the tens of millions of workers and their
families look to for compensation whenever covered accidents, diseases and
deaths occur. This stems from the development in the law that no longer is the
poor employee still arrayed against the might and power of his rich corporate
employer, hence the necessity of affording all kinds of favorable presumptions to
the employee. This reasoning is no longer good policy. It is now the trust fund
and not the employer which suffers if benefits are paid to claimants who are not
entitled under the law. The employer joins the employee in trying to have their
claims approved. The employer is spared the problem of proving a negative
proposition that the disease was not caused by employment. Moreover, the new
system instituted by the new law has discarded, among others, the concept of
"presumption of compensability and aggravation" and substituted one based on