Salmone vs. Employees' Compensation Commission

For illnesses listed as compensable occupational diseases under the Employees' Compensation Commission Rules, no further proof of causal relation between the disease and the claimant's work is necessary. The Court held that cardiovascular diseases, which include atherosclerotic heart disease, atrial fibrillation, and cardiac arrhythmia, are listed compensable occupational diseases; thus, the claimant's substantial evidence of work-related stress triggering the illness suffices to establish compensability under P.D. No. 626.

Dominga A. Salmone was employed in 1982 as a sewer by Paul Geneve Entertainment Corporation, later promoted to officer-in-charge and overall custodian of the Sewing Department, responsible for procurement and quality control. In early 1996, she began experiencing chest pains, took a leave of absence in April 1996, and was diagnosed with atherosclerotic heart disease, atrial fibrillation, and cardiac arrhythmia. Upon her doctor's recommendation for complete rest, she resigned from her employment.

• Employment: In 1982, petitioner was hired as a sewer by Paul Geneve Entertainment Corporation. She was promoted to officer-in-charge and overall custodian of the Sewing Department, handling procurement of materials and quality assurance.
• Illness: In early 1996, petitioner began suffering chest pains. By April 1996, the pains became unbearable, prompting a leave of absence. Medical examinations by Dr. Claudio Saratan, Jr. diagnosed her with Atherosclerotic Heart Disease, Atrial Fibrillation, and Cardiac Arrhythmia.
• Resignation and Claim: Following her doctor's advice for complete rest, petitioner resigned. She subsequently filed a disability claim with the SSS under P.D. No. 626.

Petitioner maintained that the nature of her employment and working conditions exacerbated the risks of contracting her cardiovascular illnesses. She argued that the ECC committed reversible error in declaring her illness was not work-connected and that her employment did not predispose her to the disease.

Respondent countered that petitioner failed to adduce substantial evidence proving any of the conditions of compensability under ECC Resolution No. 432 for cardiovascular diseases, specifically failing to prove the illness was occupational or work-connected to her position.

• Procedural Issues: N/A
• Substantive Issues:
  • Whether petitioner's illness (atherosclerotic heart disease, atrial fibrillation, cardiac arrhythmia) is compensable as a work-related occupational disease under P.D. No. 626.
  • Whether there was substantial evidence of compensability.

• Procedural: N/A
• Substantive: The Court ruled that petitioner's illness is compensable. Cardiovascular diseases are listed as compensable occupational diseases under the ECC Rules; thus, no further proof of causal relation is necessary. Even if proof were required, petitioner demonstrated by uncontroverted evidence that work-related stress caused severe chest pains leading to her diagnosis and resignation. The degree of proof required under P.D. No. 626 is merely substantial evidence, requiring only a reasonable work-connection, not direct causal relation. Probability, not certainty, is the touchstone.

• Compensability of Listed Occupational Diseases — Under P.D. No. 626 and the Amended Rules on Employees' Compensation, if a sickness is listed as an occupational disease by the Employees' Compensation Commission, no further proof of causal relation between the disease and the claimant's work is necessary. The Court applied this by classifying petitioner's atherosclerotic heart disease, atrial fibrillation, and cardiac arrhythmia under "cardiovascular diseases," which are listed compensable occupational diseases.
• Substantial Evidence in Employees' Compensation Claims — Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. The claimant must show at least by substantial evidence that the development of the disease is brought largely by the conditions present in the nature of the job. The law requires a reasonable work-connection, not a direct causal relation; probability, not certainty, is the touchstone.

• "Indisputably, cardiovascular diseases, which, as herein above-stated include atherosclerotic heart disease, atrial fibrillation, cardiac arrhythmia, are listed as compensable occupational diseases in the Rules of the Employees' Compensation Commission, hence, no further proof of casual relation between the disease and claimant's work is necessary." — This passage articulates the ratio decidendi that listed occupational diseases dispense with the need for further causal proof.
• "Probability, not certainty, is the touchtone." — This defines the standard of proof required in employees' compensation claims, emphasizing that a reasonable work-connection suffices over direct causal relation.

• Millora v. ECC, 227 Phil. 139 (1986) — Cited as controlling precedent for the rule that to be entitled to sickness benefits, the illness must either be listed as an occupational disease or proven that the risk of contracting it is increased by working conditions.
• Quizon v. ECC, 203 SCRA 426 (1991) — Followed to establish that cardiovascular diseases are listed compensable occupational diseases requiring no further proof of causal relation.
• Sarmiento v. ECC, 228 Phil. 400 (1986) — Followed for the definition of substantial evidence and the principle that probability, not certainty, is the touchstone in employees' compensation claims.

• P.D. No. 626, as amended — The governing law on employees' compensation. Applied to determine the compensability of the petitioner's illness and the degree of proof required (substantial evidence).
• ECC Resolution No. 432 (July 20, 1977) — Lists cardiovascular diseases as compensable occupational diseases provided certain conditions are met (e.g., acute exacerbation precipitated by unusual strain, strain followed within 24 hours by clinical signs of cardiac insult, or asymptomatic person showing signs of cardiac injury during work performance). The Court noted these conditions but held that because cardiovascular diseases are listed, no further proof of causal relation is necessary.

Puno, Kapunan, and Ynares-Santiago, JJ.

• Davide, Jr., C.J. — Voted to affirm the Court of Appeals' decision (details of reasoning not provided in text).