Case Summary (G.R. No. 240621)
Factual Background
Bernardo was diagnosed with Pulmonary Tuberculosis (PTB) and Community Acquired Pneumonia (CAP) in February 2004. He experienced significant health deterioration, leading to his hospital confinement from May 13 to May 19, 2004, where he was diagnosed with an acute myocardial infarction. He was found dead at the MMDA building on January 15, 2005. Following his death, Marilou filed for death benefits with the GSIS, which were ultimately denied.
GSIS Ruling and Appeal Processes
The GSIS denied Marilou’s claim based on the argument that myocardial infarction was a complication of diabetes, a condition not recognized as work-related under the law. Marilou appealed this decision to the Employees' Compensation Commission (ECC), which upheld the GSIS’s ruling. Consequently, Marilou turned to the Court of Appeals (CA) for relief, insisting that her husband's health issues, including his myocardial infarction, were aggravated by his work conditions.
Court of Appeals Decision
The CA overturned the ECC's ruling, indicating that, while myocardial infarction is not listed as an occupational disease, cardiovascular diseases could be compensable under certain conditions articulated in Resolution No. 432 by the ECC. The CA found sufficient evidence linking Bernardo's work as a laborer and metro aide to the aggravation of his health conditions, stating that the strenuous work environment contributed significantly to his ailment.
GSIS Petition for Reversal
The GSIS sought to reverse the CA decision, arguing that there was no substantial evidence linking the myocardial infarction to work-related causes and that the CA disregarded the factual determinations made by the GSIS and the ECC. They maintained the position that the myocardial infarction was merely a complication of a pre-existing non-occupational health condition.
Marilou's Counterarguments
In her response, Marilou contested the GSIS's assertions, claiming that evidence showed her husband's work conditions exacerbated his health problems. She pointed out that his diabetes alone could not account for the circumstances leading to his heart attack, highlighting earlier diagnoses of CAP and the physical strains associated with his working conditions.
Judicial Analysis and Ruling
The Court found in favor of Marilou, asserting that the prior rulings by the GSIS and ECC failed to consider the long-standing stressors linked to Bernardo's employment. The Court elaborated that workplace factors—such as workplace stress, exposure to the elements, and the nature of his physi
...continue readingCase Syllabus (G.R. No. 240621)
Overview of the Case
- The case involves a petition for review on certiorari by the Government Service Insurance System (GSIS) to annul the decision and resolution of the Court of Appeals (CA) regarding the denial of death benefits to Marilou Alcaraz after the death of her husband, Bernardo Alcaraz.
- The CA reversed the ruling of the Employees' Compensation Commission (ECC), which had denied Marilou's claim on the grounds that her husband's cause of death (myocardial infarction) was not work-related.
Antecedents
- Bernardo Alcaraz was employed for nearly 29 years at the Metro Manila Development Authority (MMDA) as a laborer and Metro aide.
- In February 2004, he was diagnosed with Pulmonary Tuberculosis (PTB) and Community Acquired Pneumonia (CAP).
- He was hospitalized on May 13, 2004, for Acute Diffuse Anterolateral Wall Myocardial Infarction, among other conditions, and discharged on May 19, 2004.
- Bernardo died on January 15, 2005, at the MMDA building, with an autopsy concluding that he died from myocardial infarction.
GSIS Ruling and Related Incidents
- The GSIS denied Marilou's claim, asserting that myocardial infarction was a complication of diabetes mellitus, a non-work-related illness.
- Marilou appealed to the ECC, which upheld the GSIS ruling.
- The CA was petitioned by Marilou, claiming misapprehension o