The Supreme Court has affirmed that employees suffering from stroke can claim compensation if their working conditions increased the risk of the illness. This decision underscores the importance of considering an employee’s actual job responsibilities, not just their job title, when evaluating compensation claims. It also reinforces the principle that in compensation proceedings, the test of proof is probability, not absolute certainty, favoring the employee’s welfare.

Beyond the Job Title: When Work Stress Leads to Stroke Compensation

In Jesus B. Villamor v. Employees’ Compensation Commission [ECC] and Social Security System, the central question revolved around whether a stroke suffered by an employee was work-related, thus entitling him to Employees’ Compensation (EC) Temporary Total Disability (TTD) benefits. The petitioner, Jesus B. Villamor, sought to overturn the Court of Appeals’ decision, which had denied his claim. The denial was based on the premise that Villamor’s stroke was not causally linked to his job as a clerk. The Supreme Court, however, found that the lower courts had erred in their assessment of Villamor’s actual duties and the stress associated with his work, ultimately ruling in his favor.

Villamor was employed by Valle Verde Country Club, Inc. (VVCCI). He was initially a waiter, then moved to the Sports Department, eventually becoming the Sports Area In-Charge. After being hospitalized due to a stroke, he sought EC TTD benefits, which were initially denied by the Social Security System (SSS) and later by the Employees’ Compensation Commission (ECC). Both agencies argued that there was no causal relationship between his illness and his working conditions. The ECC further noted that Villamor’s smoking history and drinking habits increased his risk of developing the illness.

The Supreme Court took exception to the lower courts’ findings, emphasizing that Villamor was not a mere clerk. His responsibilities as Sports Area In-Charge were more demanding than simply issuing vouchers and receipts. His job description included ensuring adherence to club rules, managing court schedules, handling member complaints, and coordinating with other departments. As such, Villamor’s duties involved both physical activity and mental pressure, requiring him to interact with diverse personalities and address their concerns. Moreover, his role as the President of the VVCCI Employees Union added another layer of stress, as he had filed several cases against VVCCI, leading to workplace harassment.

The Court referenced Section 1 (b), Rule III, of the Amended Rules on Employees’ Compensation, stating that for an illness to be compensable, it must either be an occupational disease listed in Annex ‘A’ of the rules, with the conditions satisfied, or proof must be shown that the risk of contracting the disease is increased by the working conditions. Stroke and hypertension are listed as occupational diseases under Nos. 19 and 29, respectively, of Annex “A” of the said rules.

CEREBRO-VASCULAR ACCIDENTS. Any of the following conditions:

a. There must be proof that the acute stroke must have developed as a result of the stressful nature of work and pressures inherent in an occupation.

The Court cited Government Service Insurance System v. Baul, which affirmed that cerebro-vascular accident and essential hypertension are considered occupational diseases. It’s important to note that while these conditions are listed occupational diseases, their compensability requires compliance with specific conditions. Substantial evidence is needed to validate the concurrence of these conditions. This requires a reasonable work-connection, not a direct causal relation.

Applying these principles, the Supreme Court found that Villamor was entitled to compensation. His medical reports documented his hypertension and stroke, and he demonstrated that his work and union position caused him physical and mental strain. The Court acknowledged that there was a probability that his work increased his risk of suffering a stroke. The Court underscored that direct evidence of causation is unnecessary and that the test of proof in compensation proceedings is probability, not absolute certainty.

Furthermore, the Court addressed the respondents’ argument that Villamor’s smoking and drinking habits should bar his claim. Citing Government Service Insurance System v. De Castro, the Court emphasized that these factors should not be the sole determinants of compensability. Other factors, such as age, gender, and the nature of the job, must also be considered.

We find it strange that both the ECC and the GSIS singled out the presence of smoking and drinking as the factors that rendered De Castro’s ailments, otherwise listed as occupational, to be non-compensable… However, they are not the sole causes of CAD and hypertension and, at least, not under the circumstances of the present case.

The Supreme Court ultimately ruled in favor of Villamor, ordering the Social Security System and Employees’ Compensation Commission to pay him Employees’ Compensation Temporary Total Disability benefits. The decision underscores the importance of considering the totality of an employee’s work environment and the potential for work-related stress to contribute to illnesses. It also reinforces the principle that compensation claims should be viewed with a bias toward protecting the employee’s welfare.

FAQs

What was the key issue in this case?	The key issue was whether the stroke suffered by Jesus Villamor was work-related, entitling him to Employees’ Compensation (EC) Temporary Total Disability (TTD) benefits. The court assessed whether his job duties and work environment contributed to his illness.
Why did the SSS and ECC initially deny Villamor’s claim?	The SSS and ECC denied Villamor’s claim because they found no causal relationship between his illness and his working conditions. They considered him a mere clerk and cited his smoking and drinking habits as contributing factors.
What evidence did Villamor present to support his claim?	Villamor presented his job description, which showed he was not a mere clerk but a Sports Area In-Charge with demanding responsibilities. He also showed that his union activities caused him significant stress.
What is the legal test for determining compensability in this type of case?	The legal test is whether there is a reasonable work-connection, not a direct causal relation, between the employee’s illness and their job. The test of proof is probability, not absolute certainty.
How did the Court address the issue of Villamor’s smoking and drinking habits?	The Court ruled that smoking and drinking habits should not be the sole determinants of compensability. Other factors, such as the nature of the job and potential for work-related stress, must also be considered.
What is the significance of the Government Service Insurance System v. Baul case?	The Baul case established that cerebro-vascular accident and essential hypertension are considered occupational diseases, and their compensability requires compliance with specific conditions. It emphasizes the need for substantial evidence and a reasonable work-connection.
What is the significance of the Government Service Insurance System v. De Castro case?	The De Castro case clarifies that personal habits like smoking and drinking should not automatically disqualify an employee from compensation. Other factors, like the nature of the job, must also be considered.
What was the final ruling of the Supreme Court in this case?	The Supreme Court ruled in favor of Villamor, ordering the Social Security System and Employees’ Compensation Commission to pay him Employees’ Compensation Temporary Total Disability benefits. The Court emphasized that the totality of his work environment and stress contributed to his illness.

This case highlights the importance of a comprehensive evaluation of an employee’s work environment when assessing compensation claims. It underscores the need to consider the actual duties performed and the stress associated with the job, rather than relying solely on job titles or personal habits. This ruling reinforces the pro-employee stance of Philippine labor laws, ensuring that workers receive the benefits they are entitled to under the Employees’ Compensation Act.

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: Jesus B. Villamor v. Employees’ Compensation Commission, G.R. No. 204422, November 21, 2016