Case Summary (G.R. No. 185035)
Medical Background and Claim for Benefits
De Castro was admitted to V. Luna General Hospital on December 22, 2004, because of chest pains and underwent various medical examinations, revealing serious heart conditions. Following his retirement, he received a "Certificate of Disability Discharge" and subsequently filed a claim for disability benefits with the GSIS on June 20, 2006. However, his claim was denied on the grounds that his illnesses were classified as non-occupational.
Employees' Compensation Commission (ECC) Decision
The ECC reviewed De Castro's appeal and upheld the GSIS's ruling on June 11, 2007, asserting that although coronary artery disease is acknowledged as an occupational disease, other contributing factors like smoking and alcohol consumption were present. Therefore, despite a formal recognition that his ailments were work-related, the ECC concluded his claim lacked merit due to these additional non-work-related factors.
Appeal to the Court of Appeals
De Castro filed a petition for review with the Court of Appeals, arguing that the GSIS and ECC findings inadequately addressed the nature of his work-related stress and its contributions to his medical conditions. He cited precedent establishing that if a disease is listed as occupational, the causal relationship between his condition and employment is not critical for benefit claims.
Court of Appeals’ Ruling
The Court of Appeals ruled in favor of De Castro, stating that the ECC acknowledged his conditions fall within the scope of occupational diseases. It expressed that the claimant does not need to demonstrate an explicit cause-and-effect relationship, highlighting the legal precedence that benefits must be granted if an illness is classified as occupational, notwithstanding other potential contributory factors.
GSIS’s Contentions
The GSIS contended that the Court of Appeals erred by reversing their decision, insisting that De Castro had not proved a sufficient connection between his cardiac conditions and his military service. They asserted that since the illnesses were also linked to lifestyle choices, such as smoking and drinking, he did not qualify for benefits under existing employment compensation laws.
De Castro's Defense
De Castro maintained that his conditions were indeed service-related, emphasizing that all factors contributing to his ailments, including the psychological stress of his military duties, warranted consideration. He argued that reliance solely on smoking or drinking habits overlooked the realities of military service-induced stress that could aggravate health conditions.
Analysis of the Court's Ruling
The court articulated that the evidence suggests De Castro’s long military service involved significant stress, which likely contributed to his health issues. It clarified that a mere medical link between lifestyle factors and dise
...continue readingCase Syllabus (G.R. No. 185035)
Case Citation
- G.R. No. 185035, July 15, 2009
- 610 Phil. 568
Parties Involved
- Petitioner: Government Service Insurance System (GSIS)
- Respondent: Salvador A. De Castro
Procedural Background
- The petitioner GSIS seeks the reversal of the decision and resolution of the Court of Appeals (CA) in CA-G.R. SP No. 100375.
- The case arises from a petition for review on certiorari by De Castro against the GSIS and the Employees' Compensation Commission (ECC).
Factual Antecedents
- Respondent Salvador A. De Castro served in the Philippine Air Force (PAF) from April 1, 1974, until his retirement on March 2, 2006.
- De Castro was hospitalized on December 22, 2004, due to chest pains.
- Medical examinations revealed:
- January 21, 2005: 2-D echocardiography indicated dilated left atrium, eccentric left ventricular hypertrophy, and dysfunction.
- Full diagnosis included hypertensive cardiovascular disease, dilated atrium, eccentric left ventricular hypertrophy, left ventricular dysfunction, and old anterior wall myocardial infarction.
- August 15, 2005: Further hospitalization confirmed coronary artery disease (CAD) and hypertensive cardiovascular disease.
- De Castro retired with a "Certificate of Disability Discharge" and subsequently filed a claim for permanent total disability benefits with the GSIS.
- The GSIS denied the claim on the basis that De Castro's illnesses were non-occupational.
Employees' Compensation Commission (ECC) Decision
- On June 11, 2007, the ECC affirmed the GSIS ruling, citing a lack of merit in De Castro's claim.
- The ECC acknowledged that CAD is an occupational disease but still denied the claim due to contributory