G.R. No. 225827 - Social Security System vs. Cuento

Case Summary (G.R. No. 225827)

Factual Background

BELINDA C. CUENTO sought death benefits under the Employee's Compensation Law after the death of her husband, Maximo M. Cuento. Maximo was employed as a motorized messenger by Gold Rush Services, Corp., assigned to Metro Bank; his last contract began in February 2011. He was diagnosed with a transient ischemic attack on June 15, 2011. While on duty on October 4, 2011, he lost consciousness, was brought to San Juan De Dios Hospital, and was pronounced "dead on arrival." The post mortem death certificate listed the cause of death as myocardial infarction.

Proceedings Before the SSS and ECC

BELINDA C. CUENTO filed a claim for death benefits with the SOCIAL SECURITY SYSTEM, which the SSS reviewing branch denied. The denial was sustained by the SSS Medical Operations Department. BELINDA C. CUENTO appealed the denial to the Employees' Compensation Commission.

Ruling of the Employees' Compensation Commission

The panel of the Employees' Compensation Commission affirmed the SSS denial. The ECC found no substantial evidence that Maximo had been subjected to unusual strain at work when he suffered the stroke while on duty. The ECC concluded that atherosclerosis likely caused the myocardial infarction and that the suddenness of such attacks is common in middle-aged men and can be explained by the natural progression of atherosclerosis.

Appeal to the Court of Appeals

BELINDA C. CUENTO filed a Petition for Review under Rule 43, Rules of Court, with the Court of Appeals. In its Decision dated December 17, 2015, the CA granted the petition and reversed the ECC. The CA emphasized Maximo's duties as a messenger, which required driving throughout Metro Manila to pick up and deliver checks and documents, and found that his daily exposure to heat, rain, and traffic-related pollution and stress established the strenuous nature of his work. Noting his prior transient ischemic attack, the CA concluded that the fatal myocardial infarction was work connected and therefore compensable. The CA ordered the SSS to pay the proper death benefits.

Issue Presented

The sole issue framed for resolution was whether Maximo's myocardial infarction constituted a compensable disease under PD 626, as amended, i.e., whether his fatal myocardial infarction was caused or aggravated by the unusual strain of his employment as a motorized messenger.

Parties' Contentions

The SOCIAL SECURITY SYSTEM argued that there was no proof that Maximo's myocardial infarction was caused or aggravated by his work and that BELINDA C. CUENTO failed to present substantial evidence satisfying the statutory conditions for compensability. BELINDA C. CUENTO maintained that the CA correctly found a work connection, asserting that Maximo suffered the cerebrovascular event while working and that the physical and mental stresses of plying Metro Manila traffic materially contributed to his death.

Supreme Court's Ruling

The Court denied the petition and affirmed the Court of Appeals. The Court held that the death of Maximo was due to myocardial infarction and that substantial evidence supported a finding of compensability under the relevant ECC standards and Board Resolution. The Court concluded that the case fell squarely within condition letter "b" of ECC Board Resolution No. 11-05-13, which requires that the strain of work precipitating an acute cardiac attack be of sufficient severity and be followed within twenty-four hours by clinical signs of cardiac insult; Maximo lost consciousness while on duty and died within twenty-four hours of that incident.

Legal Basis and Reasoning

The Court observed that myocardial infarction is a cardiovascular disease and that ECC Board Resolution No. 11-05-13 deems cardiovascular disease compensable when certain conditions are met, including an acute exacerbation precipitated by unusual strain and clinical manifestation within twenty-four hours. The Court set out the general requisites for compensability of occupational disease: that the employee's work or working conditions involved risks that caused the illness; that the disease was contracted as a result of exposure to those risks; that contraction occurred within a sufficient period of exposure; and that there was no deliberate disregard by the employee of safety measures. Applying these standards, the Court found substantial evidence that Maximo's continuous duties as a motorized messenger exposed him to heat, rain, and pollution and to the stresses of traffic conditions; that he had been fit to work; and that his collapse and death occurred

Case Syllabus (G.R. No. 225827)

Parties and Procedural Posture

Social Security System filed a Petition for Review on Certiorari from the Decision of the Court of Appeals in CA-G.R. SP No. 140167.
Belinda C. Cuento claimed death benefits under the Employees' Compensation Law for the death of her husband, Maximo M. Cuento.
The dispute arose from an administrative denial by SSS, an affirmation of that denial by the Employees' Compensation Commission, and a reversal by the Court of Appeals that was subject to review by the Supreme Court.

Key Factual Allegations

Maximo M. Cuento was employed as a motorized messenger by Gold Rush Services, Corp. assigned to Metro Bank and his last assignment and contract began in February 2011.
Maximo suffered a transient ischemic attack on June 15, 2011.
While on duty on October 4, 2011, Maximo suffered a stroke, was brought to San Juan De Dios Hospital, and was declared dead on arrival.
The post-mortem death certificate listed the cause of death as myocardial infarction.
Maximo's duties required driving around Metro Manila to pick up and deliver checks and documents, exposing him to heat, rain, traffic stress, and vehicular pollution.
Maximo was deemed fit to work during his employment with Metro Bank.

Procedural History

Respondent filed a claim for death benefits with SSS, which was denied by the reviewing branch and sustained by the SSS-Medical Operations Department.
Respondent appealed the denial to the Employees' Compensation Commission, which affirmed the SSS denial in ECC Case No. SM-19368-0113-15.
Respondent then filed a Petition for Review under Rule 43, Rules of Court with the Court of Appeals, which reversed the ECC decision.
SSS elevated the matter to the Supreme Court by filing a petition for certiorari.

Issue Presented

The dispositive issue was whether Maximo's myocardial infarction constituted a compensable disease under Presidential Decree No. 626, as amended.

Parties' Contentions

SSS contended that Maximo's myocardial infarction was neither caused nor aggravated by unusual strain at work and that respondent failed to adduce substantial evidence of work connection.
Belinda C. Cuento contended that Maximo suffered his fatal attack while working and that the physical strain and stress of his duties materially contributed to his sickness and eventual death.

Statutory Framework

The case invoked Presidential Decree No. 626 and the Amended Rules on Employees' Compensation as implemented by the Employees' Compensation Commission.
ECC Board Resolution No. 11-05-13 (2011) was applied to define the conditions for compensability of cardiovascular diseases, essential hypertension, and cerebrovascular accidents.
The Court applied the four-part test for