Facts:

In the case of Adelaida B. Aquino v. Social Security System and U.S. Naval Commissary Store, Subic Bay, G.R. No. 149256, decided on July 21, 2006, the petitioner, Adelaida B. Aquino, filed for certiorari against the Social Security System (SSS) and the U.S. Naval Commissary Store. The facts of the case revolve around Adelaida’s late husband, Jaime Aquino, who was employed as a grocery man at the US Navy Commissary in Subic Bay, Olongapo City, from 1970 to 1977. His responsibilities included checking stock availability, organizing items on shelves, assisting customers, and operating a forklift. After 23 years following his separation from employment, Jaime died on February 2, 2000, due to congestive heart failure. Subsequently, Adelaida sought compensation benefits under Presidential Decree (PD) No. 626 for surviving spouses. The SSS denied her claim, leading her to appeal the decision to the Employees Compensation Commission (ECC), which upheld SSS’s denial, asserting that the c

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Facts:

Background and Employment

• Petitioner Adelaida B. Aquino is the surviving spouse of Jaime Aquino, who was employed by the U.S. Navy Commissary Store in Subic Bay, Olongapo City.
• Jaime Aquino worked as a grocery man from 1970 to 1977, performing tasks that included:
• Checking the availability of stocks before their turnover to the supervisor.
• Piling items on shelves and display cases and assisting patrons.
• Processing retail price changes through inventories.
• Operating a forklift.

Death and Filing of Claim

• Approximately 23 years after his separation from employment, on February 2, 2000, Jaime Aquino died of congestive heart failure.
• Following his death, petitioner filed a claim for surviving spouse’s compensation benefits under Presidential Decree No. 626 (the Employees Compensation Act) with the Social Security System (SSS).

Procedural History

• The Social Security System (SSS) initially denied petitioner’s claim for benefits.
• Petitioner then appealed to the Employees Compensation Commission (ECC), which affirmed SSS’s decision, holding that the cause of death was not attributable to the nature of Jaime Aquino’s work.
• Aggrieved by the ECC’s ruling, petitioner elevated her appeal to the Court of Appeals (CA), insisting that her husband’s death was traceable to his work at the commissary store.
• The CA dismissed her appeal.
• Petitioner sought reconsideration of the CA decision, which was likewise denied, leading her to file a petition for certiorari with the Supreme Court under Rule 45 of the 1997 Rules of Civil Procedure.

Legal Contentions Raised by the Petitioner

• The petitioner contended that her husband’s congestive heart failure was compensable under PD No. 626 because it was, at least in part, an illness attributable to the stresses and working conditions in the commissary store.
• She argued that the nature of Jaime Aquino’s work increased the risk of contracting the cardiovascular ailment, despite the long lapse between his employment and his death.
• The petitioner faulted the CA for not recognizing a sufficient causal connection between her husband’s work and the progression of his illness.

Issue:

Whether the congestive heart failure, which caused Jaime Aquino’s death, is compensable under PD No. 626.

• Does the petitioner provide sufficient evidence that her husband’s work environment contributed to or aggravated his heart condition?
• Is the alleged causal connection between his employment and the illness adequately proven, especially considering the lapse of time?

Whether the significant time lapse (23 years) between the separation from employment and the occurrence of death undermines the claim for compensation benefits.

• Can the petitioner overcome the possibility of intervening factors that may have contributed to the claimant’s death during the long period following his separation from employment?

• Whether the findings made by the ECC and the Court of Appeals, based on administrative expertise regarding occupational diseases, should be given deference in this case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)