The Supreme Court held that the death of an employee due to myocardial infarction is compensable if the nature of the work or the working conditions contributed to or aggravated the illness, even if the employee had pre-existing conditions. This ruling underscores the state’s policy of providing maximum aid and protection to labor, ensuring that employees are compensated for illnesses that are work-related. It broadens the scope of compensable illnesses beyond those strictly listed as occupational diseases.

Beyond Diabetes: Recognizing Work-Related Stress in Myocardial Infarction Cases

This case, Government Service Insurance System vs. Marilou Alcaraz, revolves around the denial of death benefits to Marilou Alcaraz following the death of her husband, Bernardo Alcaraz, a long-time employee of the Metro Manila Development Authority (MMDA). Bernardo’s death was attributed to myocardial infarction, and the GSIS denied the claim, arguing that it was a complication of diabetes mellitus, a non-occupational disease. The central legal question is whether Bernardo’s myocardial infarction can be considered work-related, entitling his widow to death benefits, despite the presence of a pre-existing, non-occupational disease.

Bernardo Alcaraz worked for the MMDA for nearly 29 years, starting as a laborer and eventually becoming a Metro Aide I. Prior to his death, he was diagnosed with Pulmonary Tuberculosis (PTB), Community Acquired Pneumonia (CAP), and Diabetes Mellitus Type 2. He died of Myocardial Infarction at his workplace. The GSIS initially denied Marilou’s claim, stating that the cause of death was directly related to diabetes, not a work-connected illness. Marilou then appealed to the Employees’ Compensation Commission (ECC), which upheld the GSIS decision. Undeterred, Marilou sought relief from the Court of Appeals (CA), arguing that the ECC misappreciated the facts and failed to consider medical findings about her husband’s condition prior to his death. She contended that even if diabetes was an underlying cause, it was acquired and aggravated by his employment.

The CA reversed the ECC ruling, finding sufficient proof of a work-connection between Bernardo’s ailment and his working conditions. The appellate court highlighted that even though myocardial infarction is not explicitly listed as an occupational disease, the ECC’s Resolution No. 432 provides conditions under which cardiovascular diseases can be considered work-related and thus compensable. The CA emphasized the need to show a substantial connection between the job’s conditions and the disease’s development, citing Salmone v. Employees’ Compensation Commission, which stated that “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 CA believed that Bernardo’s work as a laborer and metro aide substantially contributed to his illness and ordered the GSIS to pay death benefits to his heirs.

The GSIS then elevated the case to the Supreme Court, arguing that the CA erred in finding a work-connection and disregarding the factual findings of the GSIS and ECC. The GSIS maintained that there was no evidence proving that Bernardo’s duties caused the development of myocardial infarction, as it was merely a complication of diabetes mellitus, a non-occupational disease. Marilou countered that the GSIS failed to consider that while diabetes mellitus increases the risk, so does CAP, a compensable disease that Bernardo had been diagnosed with. Further, she cited Government Service Insurance System (GSIS) v. Cuanang, emphasizing that stress is another predisposing factor for heart diseases.

The Supreme Court disagreed with the GSIS’s position, emphasizing the stressful and strenuous conditions under which Bernardo worked for almost 29 years. The Court highlighted that the GSIS and ECC disregarded other influences that contributed to Bernardo’s heart problem, worsened by the difficult working conditions he faced daily. The Court pointed to Bernardo’s exposure to the elements, pollution, and physical strain as factors that could have aggravated his condition. The CA aptly described Bernardo’s hazardous working conditions, noting his exposure to the heat, rain, and smoke, which not only resulted in myocardial infarction but also aggravated pre-existing illnesses such as pulmonary tuberculosis and community-acquired pneumonia.

The Supreme Court referenced the ECC’s Resolution No. 432, which outlines conditions under which cardiovascular diseases can be deemed work-related, stating:

18. CARDIO-VASCULAR DISEASES. Any of the following conditions:

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 reasons 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.

Building on this, the Court acknowledged that diabetes mellitus was a complicating factor but could not discount other employment factors, both mental and physical, that contributed to or aggravated his condition. It cited CAP as another potential predisposing factor and emphasized the role of stress, stating that “Stress appears to be associated with elevated blood pressure,” referencing Goverment Service Insurance System (GSIS) v. Cuanang. The Supreme Court agreed with the CA’s finding that substantial evidence supported the conclusion that myocardial infarction in Bernardo’s case was work-related.

The Court emphasized that the ECC itself included cardiovascular diseases in the list of occupational diseases, subject to conditions outlined in Resolution No. 432, making them compensable. Citing Rañises v. ECC, the Court reiterated that the incidence of acute myocardial infarction, whether or not associated with a non-listed ailment, is enough basis for compensation. The Court ultimately held that the stresses, strains, and exposure to street pollution that Bernardo endured for nearly 29 years led to a deterioration of his health, particularly with the contributing factors of diabetes and pulmonary disease. This aligns with the constitutional mandate to adopt a liberal attitude in favor of employees when deciding claims for compensability, especially where there is some basis in the facts for inferring a work-connection to the illness.

FAQs

What was the key issue in this case?	The key issue was whether the death of Bernardo Alcaraz due to myocardial infarction was compensable, considering his pre-existing condition of diabetes mellitus, which the GSIS claimed was not work-related. The Court had to determine if his working conditions contributed to or aggravated his illness.
What did the GSIS argue?	The GSIS argued that myocardial infarction was a complication of diabetes mellitus, a non-occupational disease, and therefore, Bernardo’s death was not work-related. They asserted there was no evidence showing his work duties caused the heart condition.
What did the Court of Appeals decide?	The Court of Appeals reversed the ECC’s decision, finding sufficient proof of a work-connection between Bernardo’s ailment and his working conditions. They cited ECC Resolution No. 432, which allows for the compensability of cardiovascular diseases under certain conditions.
What was ECC Resolution No. 432?	ECC Resolution No. 432 outlines conditions under which cardiovascular diseases can be considered work-related and thus compensable. These conditions include proof that an acute exacerbation was clearly precipitated by the unusual strain of work, or that symptoms of cardiac injury appeared during work performance.
What role did stress play in the Supreme Court’s decision?	The Supreme Court acknowledged that stress due to the nature of Bernardo’s work was a significant factor contributing to his myocardial infarction. The Court referenced past rulings recognizing the association between stress and elevated blood pressure, a predisposing factor for heart diseases.
What is the significance of the *Salmone v. Employees’ Compensation Commission* case?	*Salmone v. Employees’ Compensation Commission* was cited to emphasize that a claimant must show, with substantial evidence, that the conditions of their job largely contributed to the development of the disease. This highlights the need to establish a clear link between the work environment and the illness.
How does the Supreme Court view claims for compensation?	The Supreme Court emphasizes that agencies like the ECC, GSIS, and SSS should adopt a liberal attitude in favor of employees when deciding claims for compensability. This is especially true when there is some basis in the facts for inferring a work-connection to the illness or accident.
What other illnesses did Bernardo have, and how did they affect the decision?	Bernardo was diagnosed with Pulmonary Tuberculosis (PTB) and Community Acquired Pneumonia (CAP), in addition to diabetes. The Court considered these illnesses, particularly CAP, as potential predisposing factors to myocardial infarction, further supporting the claim that his death was work-related.

In conclusion, the Supreme Court’s decision in GSIS v. Alcaraz reinforces the principle that employees are entitled to compensation for illnesses aggravated or caused by their working conditions, even if pre-existing conditions are present. This ruling serves as a reminder to the GSIS and ECC to adopt a more liberal approach in assessing claims, ensuring that the State’s policy of protecting labor is upheld.

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: GOVERNMENT SERVICE INSURANCE SYSTEM VS. MARILOU ALCARAZ, G.R. No. 187474, February 06, 2013