G.R. No. 166261 - Government Service Insurance System vs. Corrales

Respondent, Astrid V. Corrales, was employed with the Commission on Audit (COA).
She initially served as a Messenger (appointed April 4, 1989), later as a Junior Process Server (appointed September 8, 1994), and was eventually promoted to Clerk III on May 28, 1998.

On May 15, 2002, respondent was confined at the Philippine Heart Center (PHC) for treatment due to a congenital heart condition described as "Congenital Heart Disease (CHD), ASD, predominantly L-R Shunt with QpQs of 1.6:1, severe PHPN Functional Class III".
She underwent surgery and was discharged on June 5, 2002.
It was revealed in her clinical abstract that although she had a suspected heart ailment in 1972, she remained asymptomatic for a long period, with evident manifestation of symptoms (such as easy fatigability and shortness of breath) appearing only around the year 2000, two years after her promotion to Clerk III.

Respondent filed a claim for disability benefits under Presidential Decree (P.D.) No. 626 for P493,682.24, representing the cost of hospitalization.
GSIS, as her employer and petitioner in the case, denied the claim on the ground that her disability was non-compensable since it was attributed to an ailment not considered an occupational disease, emphasizing its congenital and pre-existing nature.

Proceedings Before the Employees’ Compensation Commission (ECC) and the Court of Appeals (CA)

The ECC, in its January 29, 2004 Decision, held that the CHD was a pre-existing, non-work-related condition based on medical studies that indicated its congenital (genetic) origin, and thus, not compensable.
Dissatisfied with the ECC ruling, respondent appealed to the CA, arguing that CHD is a form of cardiovascular disease—a disease included in the list of compensable conditions under Annex "A" of the Amended Rules on Employees’ Compensation.
The CA, in its August 23, 2004 Decision, reversed the ECC’s ruling by holding that:

Medical evidence established that CHD, while congenital, falls under the generic term "cardiovascular diseases" as listed in Annex "A".
Compensability was further supported by the fact that respondent, previously asymptomatic, displayed signs and symptoms after her promotion to Clerk III, when her work involved more strenuous and physically demanding duties.

The CA further reinforced its decision by emphasizing the social justice policy of the Constitution, supporting an interpretation favorable to the working man.
GSIS filed a motion for reconsideration which was denied by the CA on October 29, 2004, maintaining that the CHD claim was valid.

The ECC’s initial decision did not account for the specific duties performed by respondent in the Procurement Division of the COA.
Respondent’s assigned tasks included strenuous activities such as conducting physical inventories, canvassing for supplies and equipment, and reconciling property balances—all of which were markedly more demanding than her previous, less strenuous roles.
Evidence, including a certification from the Chief of the Procurement Division, corroborated the claim that her work duties were physically demanding, thus creating a causal link between those duties and the manifestation of her CHD symptoms.

Whether the Court of Appeals erred in reversing the Employees’ Compensation Commission’s decision denying respondent’s claim for disability benefits.
Whether the congenital heart disease (CHD) suffered by respondent, despite its congenital and pre-existing nature, qualifies as an occupational disease under P.D. No. 626.
Whether the aggravation of a pre-existing condition (CHD), manifested after subjecting to more strenuous work conditions following her promotion, establishes a work-related causal relationship sufficient for compensation.
Whether the application of a presumption of compensability for occupational diseases, as dictated by the generic usage of “cardiovascular diseases” in Annex "A", applies even when the disease in question is congenital in origin.