Case Digest (G.R. No. 185035)
Facts:
Government Service Insurance System v. Salvador A. De Castro, G.R. No. 185035, July 15, 2009, the Supreme Court Second Division, Brion, J., writing for the Court.Petitioner Government Service Insurance System (GSIS) sought review of the Court of Appeals decision in CA-G.R. SP No. 100375 that had granted respondent Salvador A. De Castro's petition for employees' compensation benefits and reversed the Employees' Compensation Commission's (ECC) dismissal of his claim.
Salvador A. De Castro served in the Philippine Air Force from April 1, 1974 until his retirement by disability discharge on March 2, 2006. He was admitted to V. Luna General Hospital on December 22, 2004 for chest pains; diagnostic studies (including 2‑D echocardiography and coronary angiogram) showed dilated left atrium, left ventricular hypertrophy and dysfunction, old anterior wall myocardial infarction, and significant single‑vessel coronary artery disease (CAD). He was again confined on August 15, 2005 with diagnoses of CAD and hypertensive cardiovascular disease. The AFP Disability and Separation Board (DSB) certified that his ailments were aggravated by and incident to service and issued a Certificate of Disability Discharge upon separation.
De Castro filed a claim for permanent total disability benefits with GSIS, which in a June 20, 2006 decision denied the claim as non‑occupational. On appeal the ECC (Board meeting June 11, 2007) affirmed the GSIS dismissal for lack of merit but conceded that CAD is listed among occupational diseases in Annex “A” of the Amended ECC Rules; it nevertheless denied compensation because it found non‑work‑related contributing factors (notably smoking and alcohol consumption). De Castro then petitioned the Court of Appeals (CA) under Rule 43; the CA (decision promulgated July 16, 2008) granted the petition, held that CAD and essential hypertension are included in Annex “A” and that listing sufficed to establish compensability without strict proof of cau...(Pro-only)
Issues:
- Is a petition under Rule 45 of the Rules of Court the proper mode of review where the CA affirmed compensability on given facts (i.e., is the controversy a question of law)?
- Were De Castro’s heart ailments compensable as occupational diseases — i.e., did he prove a sufficient work connection such that GSIS and the ECC erred in denying his claim because...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)