Title
Government Service Insurance System vs. Esteves
Case
G.R. No. 182297
Decision Date
Jun 21, 2017
Utility worker's death from diabetes-related complications deemed non-compensable under P.D. No. 626, as work conditions did not increase disease risk.

Case Digest (G.R. No. 182297)

Facts:

Government Service Insurance System v. Fe L. Esteves, G.R. No. 182297, June 21, 2017, Supreme Court Third Division, Velasco Jr., J., writing for the Court.

Petitioner Government Service Insurance System (GSIS) seeks review of the Court of Appeals (CA) decision that reversed the Employees' Compensation Commission's (ECC) dismissal of respondent Fe L. Esteves' claim for death benefits following the August 5, 2000 death of her husband, Antonio Esteves, Sr. Antonio was a utility worker at Gubat District Hospital (GDH), Gubat, Sorsogon, from December 1978 until his death. His duties included preparing beds, cleaning wards, carrying patients, distributing linens, and running errands for medical staff.

On August 5, 2000 Antonio was rushed to GDH for body weakness, headache and vomiting. Hospital records showed fluctuating high blood pressures (reported ranges up to 200 mmHg) and markedly elevated blood sugar values (ranging from 10.44 mmol/L to 21.95 mmol/L). He died a few hours after admission. The death certificate listed: immediate cause—“CVA, HEMORRHAGIC”; antecedent—“HYPERTENSION, STAGE III”; underlying—“NIDDM” (Non‑Insulin Dependent Diabetes Mellitus).

Respondent filed for death benefits under P.D. No. 626. GSIS denied the claim on the ground that the underlying disease, Diabetes Mellitus, is not work‑related. The ECC affirmed GSIS’s denial in its April 20, 2005 Decision, reasoning that medical evidence showed diabetes as the primary disease and that diabetes is not occupationally connected to the deceased’s employment; hypertension and stroke were complications of diabetes and could have occurred irrespective of working conditions. Respondent appealed to the CA.

The CA, in a Decision dated December 13, 2007, reversed the ECC and ordered GSIS to pay death benefits, finding that the death certificate and several physicians’ affidavits sufficiently supported compensability and that the dece...(Subscriber-Only)

Issues:

  • Did the Court of Appeals commit reversible error in overturning the ECC Decision that denied respondent Fe L. Esteves death benefits under P.D. No. 626, as amended?
  • Can the underlying cause of death identified as Diabetes Mellitus and its complications (hypertension and cerebrovascular accident) be considered compensable under P.D. No. 626, as amended, g...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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