G.R. No. 185035 - Government Service Insurance System vs. De Castro

Respondent Salvador A. De Castro served in the Philippine Air Force (PAF) from April 1, 1974 until his retirement on March 2, 2006.
While in service, De Castro experienced chest pains and underwent several medical examinations, including a 2-D echocardiography and coronary angiogram, which revealed significant cardiac abnormalities such as a dilated left atrium, eccentric left ventricular hypertrophy, left ventricular dysfunction, and coronary artery disease (CAD).
Detailed diagnoses included hypertensive cardiovascular disease, evidence of an old anterior wall myocardial infarction, and CAD. Later, on August 15, 2005, further confinement and diagnosis affirmed the presence of coronary artery disease and hypertensive cardiovascular disease.

Following his retirement, with a Certificate of Disability Discharge indicating that his cardiac conditions were aggravated during his active service, De Castro filed a claim for permanent total disability benefits with the Government Service Insurance System (GSIS).
In a June 20, 2006 decision, the GSIS denied his claim on the ground that his illnesses were non-occupational; i.e., not causally connected to his employment.
De Castro subsequently appealed to the Employees’ Compensation Commission (ECC), where the ECC Board, at a June 11, 2007 meeting, affirmed the GSIS ruling by dismissing the claim for lack of merit.
Notably, the ECC also observed that, although CAD is included in the list of occupational diseases, De Castro’s claim was dismissed due to factors such as his smoking and alcohol consumption and the suggestion that his cardiomyopathy might be related to these habits.

De Castro petitioned the Court of Appeals (CA) under Rule 43 for review of the preceding decisions, arguing that his illnesses being listed as occupational diseases under Annex “A” of the Amended ECC Rules is sufficient to deem them compensable.
The CA granted the petition. The court emphasized that:

Listed diseases require only a reasonable work connection rather than a direct causal relationship.
The certificate of disability discharge as issued by the AFP, along with findings that his ailments were aggravated during service, provided significant evidence establishing work connection.

The GSIS then filed a petition for review on certiorari before the Supreme Court, challenging the CA’s reversal of the previous administrative rulings.

Merely being on the list of occupational diseases is not sufficient; all conditions/requisites under Item No. 18 of Annex “A” must be met.
There must be evidence of an acute exacerbation directly precipitated by an unusual strain associated with work.
The findings regarding De Castro’s lifestyle (smoking and drinking) were pivotal in determining that his illness was not work-related.

No further proof beyond the listing as an occupational disease is necessary, as evidenced by precedents such as Dominga A. Salmone v. ECC.
The working conditions, stress, and the very nature of his military duties contributed to his cardiovascular ailments.
The military’s findings, including his certificate of disability discharge, supported that his illnesses were incurred during active service.
The CA’s determination, which relied on the totality of circumstances rather than solely on medical lifestyle factors, was a correct approach.

Whether the Court of Appeals erred in reversing the decisions of the ECC and the GSIS by not requiring a strict, direct causal relation between work and illness.
Whether De Castro adequately proved that his heart ailments were work-connected and precipitated by his duties in the AFP.

Whether being listed as an occupational disease in Annex “A” of the Amended ECC Rules automatically renders an illness compensable, regardless of other contributing personal factors such as smoking and alcohol consumption.
Whether the GSIS's insistence on additional conditions (such as the presence of an acute exacerbation triggered by work-related strain) is necessary for compensability.

Whether the petition under Rule 45, which limits review primarily to questions of law, is appropriate when factual findings of the CA are challenged.
The extent to which factual findings, particularly the military certification and discharge documentation, are reviewable under a petition for review on certiorari.