GSIS vs. Alcaraz

A cardiovascular disease is compensable under Presidential Decree No. 626 when the nature of the employee's work and the conditions under which they labored precipitated an acute exacerbation of the heart condition, even if non-occupational diseases like diabetes mellitus were concurrent complicating factors.

Bernardo Alcaraz was employed as a laborer and Metro Aide I by the Metro Manila Development Authority (MMDA) in Makati City for nearly 29 years. Sometime in February 2004, he was diagnosed with Pulmonary Tuberculosis (PTB) and Community Acquired Pneumonia (CAP). He was confined at the Ospital ng Makati from May 13 to 19, 2004, with a diagnosis of Acute Diffuse Anterolateral Wall Myocardial Infarction, CAP High Risk, PTB III, and Diabetes Mellitus Type 2. On January 15, 2005, Bernardo was found dead at the basement of the MMDA building. An autopsy concluded that the cause of death was Myocardial Infarction, old and recent.

• Employment and Working Conditions: Bernardo Alcaraz worked for the MMDA from July 1, 1976, to January 15, 2005, as a laborer and Metro Aide I. His duties required daily exposure to the sweltering heat, rain, and vehicular smoke on the streets of Makati City.
• Medical History: In February 2004, Bernardo was diagnosed with PTB and CAP. By May 3, 2004, he was experiencing shortness of breath and dizziness but continued working. He was confined at the Ospital ng Makati from May 13 to 19, 2004, diagnosed with Acute Diffuse Anterolateral Wall Myocardial Infarction, CAP High Risk, PTB III, and Diabetes Mellitus Type 2.
• Death: On January 15, 2005, Bernardo was found dead at the basement of the MMDA building while at work. An autopsy by the Southern Police District Crime Laboratory established the cause of death as Myocardial Infarction, old and recent.

• Non-Compensability of Illness: Petitioner GSIS argued that myocardial infarction, the cause of death, was not work-connected but was a complication of diabetes mellitus, a non-occupational disease.
• Lack of Causal Link: Petitioner maintained that no evidence demonstrated that the performance of Bernardo's duties caused the development of myocardial infarction or increased the risk of contracting it.
• Disregard of Administrative Findings: Petitioner faulted the Court of Appeals for disregarding the factual findings of the GSIS and the ECC, which are ordinarily accorded respect by the courts.

• Aggravation by Working Conditions: Respondent Marilou Alcaraz contended that the nature of Bernardo's work—constant exposure to the elements and vehicular pollution—aggravated his pre-existing illnesses and increased the risk of contracting myocardial infarction.
• Other Predisposing Factors: Respondent argued that diabetes mellitus was not the sole predisposing factor; CAP, a compensable disease, and physical stress were also present and contributed to the heart condition.
• Compensability Under Existing Rules: Respondent maintained that the incidence of acute myocardial infarction, whether or not associated with a non-listed ailment, is a sufficient basis for requiring compensation under existing jurisprudence and ECC rules.

• Compensability of Illness: Whether Bernardo's myocardial infarction is compensable despite the GSIS and ECC's finding that it was a complication of diabetes mellitus, a non-occupational disease.
• Factual Findings of Administrative Agencies: Whether the Court of Appeals erred in reversing the factual findings of the GSIS and ECC regarding the work-connection of the illness.

• Compensability of Illness: Myocardial infarction was ruled compensable. The conclusion that the ailment was simply a complication of diabetes mellitus disregarded the stressful and strenuous conditions of Bernardo's work as a metro aide. The nature of his duties and his exposure to street pollution and the elements for nearly 29 years constituted substantial evidence that his working conditions precipitated the acute exacerbation of his heart condition. Under ECC Resolution No. 432, a heart disease is compensable if an acute exacerbation was clearly precipitated by the unusual strain by reason of the nature of the work. Furthermore, other predisposing factors such as CAP and work-related stress could not be discounted.
• Factual Findings of Administrative Agencies: The reversal of the GSIS and ECC factual findings was upheld. The Court of Appeals committed no reversible error or grave abuse of discretion because substantial evidence supported the conclusion that the risks present in Bernardo's work environment precipitated his fatal myocardial infarction.

• Liberal Interpretation of Employees' Compensation Laws — The Employees' Compensation Commission, GSIS, and SSS are mandated to adopt a liberal attitude in favor of employees in deciding claims for compensability, especially where there is some basis in the facts for inferring a work-connection to the illness. This is in consonance with the State policy to give maximum aid and protection to labor.
• Compensability of Cardio-Vascular Diseases (ECC Resolution No. 432) — Cardio-vascular diseases are considered work-related and compensable if any of the following conditions are met: (a) If the heart disease was known to have been present during employment, there must be proof that an acute exacerbation was clearly precipitated by the unusual strain by reason of the nature of his/her work; (b) The strain of work that brings about an acute attack must be of sufficient severity and must be followed within twenty-four hours by the clinical signs of a cardiac insult to constitute causal relationship; (c) If a person who was apparently asymptomatic before being subjected to strain at work showed signs and symptoms of cardiac injury during the performance of his/her work and such symptoms and signs persisted, it is reasonable to claim a causal relationship.

• "While diabetes mellitus was indeed a complicating factor in Bernardo’s health condition and indisputably aggravated his heart problem, we cannot discount other employment factors, mental and physical, that had been indisputably present; they contributed, if not as a direct cause of the heart condition itself, as aggravation that worsened and hastened his fatal myocardial infarction."
• "As a final point, we take this occasion to reiterate that as an agency charged by law with the implementation of social justice guaranteed and secured by the Constitution – the ECC (as well as the GSIS and the SSS) – should adopt a liberal attitude in favor of the employees in deciding claims for compensability, especially where there is some basis in the facts for inferring a work-connection to the accident or to the illness."

• Salmone v. Employees’ Compensation Commission, 395 Phil. 341 (2000) — Followed; the claimant must show by substantial evidence that the development of the disease is brought largely by the conditions present in the nature of the job.
• Government Service Insurance System (GSIS) v. Cuanang, G.R. No. 158846, June 3, 2004, 430 SCRA 639 — Followed; recognized that stress is a predisposing factor for myocardial infarction.
• Rañises v. Employees Compensation Commission, 504 Phil. 340 (2005) — Followed; the incidence of acute myocardial infarction, whether or not associated with a non-listed ailment, is enough basis for requiring compensation.

• Presidential Decree No. 626 — Amends Book IV of the Labor Code governing the employees' compensation program. Applied to reinforce the State policy of extending compensation benefits to a greater number of employees and adopting a liberal stance in favor of labor.
• Annex "A" of the Amended Rules on Employees Compensation (ECC Resolution No. 432) — Lists occupational diseases and conditions for compensability. Specifically, Item No. 18 on Cardio-Vascular Diseases was applied to establish that Bernardo's heart condition was compensable because his work conditions precipitated the acute exacerbation.

Antonio T. Carpio, Mariano C. del Castillo, Jose Portugal Perez, Estela M. Perlas-Bernabe.