Social Security System vs. Cuento

A motorized messenger's fatal myocardial infarction is compensable under PD 626 where the strain of work — daily exposure to heat, rain, and pollution while driving around Metro Manila — was of sufficient severity and was followed within 24 hours by the clinical signs of cardiac insult, satisfying condition (b) of ECC Board Resolution No. 11-05-13.

Respondent Belinda C. Cuento is the widow of Maximo M. Cuento, who was employed as a motorized messenger by Gold Rush Services, Corp. and assigned to Metro Bank. The claim for death benefits was filed under the Employees' Compensation Law (Presidential Decree No. 626, as amended), which governs compensation for work-related death or disability of private-sector employees. The Social Security System (SSS) serves as the initial reviewing body for such claims, with the Employees' Compensation Commission (ECC) as the appellate level, and the Court of Appeals exercising further review via Rule 43.

Maximo M. Cuento was employed as a motorized messenger by Gold Rush Services, Corp., assigned to Metro Bank. His duties included driving around Metro Manila to pick up checks and documents for delivery to the head office of Metro Bank and to deliver documents to its various branches. His last assignment and contract was in February 2011. On June 15, 2011, Maximo was diagnosed with a transient ischemic attack, a condition that placed him at risk of myocardial infarction.

On October 4, 2011, while on duty, Maximo appeared to have suffered a stroke. He was brought to San Juan De Dios Hospital, where he was declared "dead on arrival." The Post Mortem Death Certificate listed myocardial infarction as the cause of death. He had been deemed fit to work.

Respondent Belinda C. Cuento, Maximo's widow, filed a claim for death benefits with the SSS. The reviewing branch denied the claim, and the SSS-Medical Operations Department sustained the denial. On appeal, the ECC affirmed the denial, reasoning that there was no showing Maximo had been subjected to unusual strain at work when he suffered the stroke, and that the suddenness of the attack was common in middle-aged or elderly men and could be explained by the typical progress of atherosclerosis over time. The CA, however, reversed the ECC, taking into account Maximo's daily exposure to the heat of the sun, rain, pollution, and the strenuous nature of his work as a motorized messenger, and finding his myocardial infarction work-connected and compensable.

• No Work Connection: Petitioner SSS argued that Maximo's myocardial infarction was neither caused nor aggravated by the unusual strain of his job as a motorized messenger.
• Insufficient Evidence: Petitioner maintained that respondent utterly failed to adduce substantial evidence showing that the conditions of the law for compensability were complied with.
• No Proof of Compensability: Petitioner asserted that without proof of work connection, the deceased's myocardial infarction cannot be declared compensable under PD 626.

• CA Correctly Reversed the ECC: Respondent asserted that the CA correctly reversed the ECC ruling, as it was undisputed that Maximo suffered a stroke while working.
• Job Contributed to Sickness and Death: Respondent argued that Maximo's duties as a motorized messenger undoubtedly contributed to the physical effects on his health and body because of his exposure to constant stress brought about by traffic and infuriating fellow motorists, and that his job clearly contributed to his sickness and eventual death.

• Compensability of Myocardial Infarction: Whether Maximo's myocardial infarction is a compensable disease under PD 626, as amended.

• Compensability of Myocardial Infarction: Yes. The death of respondent's husband is compensable, the conditions for compensability of cardiovascular diseases under ECC Board Resolution No. 11-05-13 being satisfied, specifically condition (b): the strain of work that brings about an acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of cardiac insult to constitute causal relationship.

• Compensability of Myocardial Infarction: Myocardial infarction falls under the umbrella of cardiovascular diseases, the compensability of which is governed by ECC Board Resolution No. 11-05-13. Under that resolution, a cardiovascular disease is deemed compensable if, among other conditions, "the strain of work that brings about an acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship" (condition b). Maximo was on duty as a motorized messenger when he suffered loss of consciousness, and within 24 hours he died due to myocardial infarction. His duties required him to drive around Metro Manila delivering documents to and from Metro Bank branches, exposing him daily to the heat of the sun, rain, and pollution — factors that the Court deemed principal and which cannot be ignored in declaring compensability. The Court applied the four general conditions for compensability under PD 626: (1) the working conditions involved risks of contracting the illness; (2) the disease was contracted as a result of exposure to those risks; (3) the disease was contracted within the period of exposure and under necessary factors; and (4) there was no deliberate act by the employee to disregard safety measures. All four were satisfied. The Court relied on Rañises vs. Employees Compensation Commission, which held that a driver-messenger subject to severe strain and fatigue from everyday traffic had a compensable ailment. The Court further invoked the principle from GSIS vs. Cuanang that the ECC, SSS, and GSIS should 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, as mandated by the Constitution's social justice guarantees.

• Liberal Construction of Employees' Compensation Law — The ECC, SSS, and GSIS, as agencies charged by law with implementing the social justice guaranteed by the Constitution, should 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. The Court applied this principle to uphold the compensability of Maximo's myocardial infarction despite the SSS and ECC's denial.
• Compensability of Cardiovascular Diseases (ECC Board Resolution No. 11-05-13) — A cardiovascular disease is deemed a compensable occupational disease under any of three conditions: (a) if the heart disease was known to be present during employment, there must be proof that an acute exacerbation was clearly precipitated by unusual strain by reason of the nature of work; (b) the strain of work that brings about an acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship; and (c) if a person who was apparently asymptomatic before being subjected to strain at work showed signs and symptoms of cardiac impairment during the performance of work and such symptoms persisted, it is reasonable to claim a causal relationship, subject to conditions regarding hypertension status and prior health examination results. The Court applied condition (b) to the facts.
• Four Conditions for Compensability under PD 626 — For an occupational or work-related disease and the resulting disability or death to be compensable, all four conditions must be satisfied: (1) the employee's work and/or working conditions must involve risks that caused the development of the illness; (2) the disease was contracted as a result of the employee's exposure to the described risks; (3) the disease was contracted within a period of exposure and under such factors necessary to contract it; and (4) there was no deliberate act on the part of the employee to disregard safety measures or ignore established warning or precaution.

• "Daily exposure to the heat of the sun, rain, and pollution are principal factors that cannot simply be ignored in declaring the compensability of the death of respondent's husband." — This passage articulates the Court's reasoning that the ordinary but sustained environmental hazards of a motorized messenger's daily work constitute the requisite strain for compensability under the Employees' Compensation Law.
• "As a final note, the Court in the case of GSIS v. Cuanang declared 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." — This passage restates the constitutional mandate for liberal construction of compensation claims, frequently cited in subsequent employees' compensation jurisprudence.
• "The only plausible conclusion in the instant case is that respondent's husband worked under risks of stress and strain that greatly contributed to his myocardial infarction. A reasonable mind analyzing these facts cannot but conclude that the risks present in respondent's husband working environment for the entire duration of his employment precipitated the myocardial infarction that led to his death." — This passage sets forth the Court's ultimate factual conclusion linking the working environment to the fatal cardiac event.

• Rañises vs. Employees Compensation Commission, 504 Phil. 340 (2005) — Controlling precedent followed. The Court held that a driver-messenger who spent virtually his whole day driving around Metro Manila, delivering equipment, collecting checks, and picking up guests, was subject to severe strain and fatigue and exposed to the stress of everyday traffic, rendering his ailment compensable. The Court found the present case analogous and applied the same reasoning.
• GSIS vs. Cuanang, 474 Phil. 727 (2004) — Cited for the doctrine that the ECC, SSS, and GSIS should adopt a liberal attitude in favor of employees in deciding claims for compensability, consistent with the Constitution's social justice guarantees. The Court relied on this principle to uphold compensability.
• Nitura vs. Employee's Compensation Commission, 278 Phil. 302 (1991) — Cited within GSIS vs. Cuanang as supporting authority for the liberal construction doctrine.

• Presidential Decree No. 626 (Employees' Compensation Law), as amended — Governs compensation for work-related death or disability of private-sector employees. The Court applied the four conditions for compensability: (1) work/working conditions involve risks causing the illness; (2) disease contracted as a result of exposure to those risks; (3) disease contracted within the period of exposure and under necessary factors; (4) no deliberate act by the employee to disregard safety measures.
• ECC Board Resolution No. 11-05-13 (2011), "Amending the Conditions for Compensability of Cardiovascular Diseases, Essential Hypertension, and Cerebrovascular Accidents Under Annex 'A' of the Amended Rules on Employees' Compensation" — Sets forth the conditions under which cardiovascular diseases are deemed compensable occupational diseases. The Court applied condition (b): the strain of work bringing about an acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship.

Perlas-Bernabe (Chairperson), Hernando, Gaerlan, and Rosario, JJ., concurred.