In Leviste v. SSS, the Supreme Court ruled that ‘sudden cardiac death’ is presumed work-related under Employees’ Compensation Law if specific conditions are met, entitling the claimant to death benefits. This decision shifts the burden of proof from the claimant to the Social Security System (SSS), especially when the employee’s death occurs shortly after strenuous work or manifests cardiac symptoms during work. The ruling underscores the importance of considering the working conditions and circumstances surrounding an employee’s death when evaluating claims for compensation, thereby safeguarding the rights of employees and their families.

From Workplace Strain to Loss: Establishing Causation in Cardiac Arrest Cases

This case centers on Gina Leviste’s claim for death benefits following the ‘sudden cardiac death’ of her husband, Ronald Leviste, a supervisor at Solid Mills, Inc. The Social Security System (SSS) initially denied the claim, arguing that Ronald’s death was not work-related. However, the Supreme Court reversed the decision, emphasizing that the Employees’ Compensation Commission (ECC) had included cardiovascular diseases in its list of compensable illnesses. This inclusion creates a presumption that ‘sudden cardiac death’ is work-related, provided it occurs under certain conditions. The crucial legal question is whether Ronald Leviste’s death met those conditions, thereby entitling his widow to benefits.

The heart of the matter lies in whether Ronald’s ‘sudden cardiac death’ was linked to his employment conditions at Solid Mills. To fully grasp the implications, understanding the conditions under which cardiovascular diseases are deemed work-related is critical. The ECC requires proof that the heart disease either pre-existed and was exacerbated by work strain, or that the fatal cardiac event occurred within 24 hours of significant work-related strain. Moreover, a causal relationship can be established if symptoms of cardiac injury manifested during work performance. The determination hinges on the nature of Ronald’s work, any pre-existing conditions, and the timing of his death relative to his work activities.

Petitioner Gina Leviste argued that her husband’s death met the requirements for compensability because of his strenuous work conditions. Solid Mills’ own records indicated that Ronald’s work involved exposure to disagreeable elements like dust, fumes, and heat. Co-workers testified to the physically demanding tasks Ronald regularly performed, including lifting heavy equipment and repairing machinery, on the day of his death, Ronald helped move a 100-kilo air-conditioning compressor, skipped lunch due to feeling unwell, and came home exhausted. The Court placed significant weight on the evidence of strenuous work, as reported in his working conditions, including regular exposure to dust, dirt, fumes, grease, and heat. The affidavit of his co-workers further corroborated his strenuous work.

Building on this, the Supreme Court underscored that strict rules of evidence do not govern claims for workmen’s compensation; instead, the standard is merely substantial evidence supporting a conclusion. The Court highlighted the report from Solid Mills itself, acknowledging Ronald’s death was due to ‘cardiac arrest secondary to overfatigue’. This acknowledgement, coupled with evidence of his work conditions, created a reasonable probability that his death was work-related. The fact that his death occurred within 24 hours of heavy physical exertion, compounded by the manifestation of fatigue and discomfort, was critical to the Court’s analysis.

The Supreme Court emphasized that the Employees’ Compensation Law is designed to protect workers and their families. It stated that, although he had no prior heart issues, the physical strain he endured both regularly and on the day he passed contributed to his ‘sudden cardiac death.’ Because his role involved heavy lifting and machinery repair under adverse environmental factors, the court decided in favor of his widow, citing substantial evidence. The Supreme Court also cited the case of Ranises v. Employees’ Compensation Commission to bolster its position that a previously asymptomatic individual who exhibits signs of cardiac injury during work and whose symptoms persist, may claim a causal relationship between work and ailment.

The ultimate decision was a resounding victory for the petitioner. By reversing the CA’s decision, the Supreme Court explicitly ordered the Social Security System to pay Gina Leviste the compensation benefits due to her under P.D. No. 626, as amended. It’s a call to prioritize employee welfare when evaluating death benefit claims.

FAQs

What was the key issue in this case?	The key issue was whether the ‘sudden cardiac death’ of Gina Leviste’s husband was work-related and thus compensable under the Employees’ Compensation Law.
What did the Court rule?	The Supreme Court ruled in favor of Gina Leviste, stating that her husband’s death was presumed to be work-related given the strenuous nature of his job and the circumstances surrounding his death.
What is the significance of ECC Resolution No. 432?	ECC Resolution No. 432 includes cardio-vascular diseases in the List of Occupational and Compensable Diseases, creating a presumption that ‘sudden cardiac death’ is work-related under certain conditions.
What conditions must be met for cardio-vascular disease to be considered work-related?	The heart disease must have been exacerbated by work strain, or the cardiac event must occur within 24 hours of strenuous work, or symptoms of cardiac injury must manifest during work.
What evidence did Gina Leviste present?	Gina Leviste presented the death certificate, job specifications, co-worker affidavits detailing strenuous work, and her own affidavit regarding her husband’s condition before his death.
What standard of evidence is required in workmen’s compensation claims?	The standard is substantial evidence, which means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, and not strict proof.
What did the Social Security System (SSS) have to do?	The Supreme Court ordered the SSS to pay Gina Leviste the compensation benefits due to her under P.D. No. 626, as amended.
How does this ruling protect workers?	The ruling reinforces the Employees’ Compensation Law’s protective intent, ensuring that employees and their families receive benefits when death is linked to work-related conditions.

This landmark decision serves as a reminder of the importance of protecting the rights of workers and ensuring that their families are provided for in the event of work-related death or injury. The court’s emphasis on substantial evidence and the presumption of compensability offers a crucial safeguard for employees and sets a precedent for future claims.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Leviste v. SSS, G.R. No. 159060, November 28, 2007