GR 142392; (September, 2000) (Digest)
G.R. No. 142392; September 26, 2000
DOMINGA A. SALMONE, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and SOCIAL SECURITY SYSTEM, respondents.
FACTS
Petitioner Dominga A. Salmone was employed by Paul Geneve Entertainment Corporation, initially as a sewer and later promoted to officer-in-charge and overall custodian of the Sewing Department. Her duties involved procurement and quality control, exposing her to constant physical stress and psychological pressure. In early 1996, she began experiencing severe chest pains, leading to a leave of absence in April 1996. Medical examination diagnosed her with atherosclerotic heart disease, atrial fibrillation, and cardiac arrhythmia. Following her doctor’s advice for complete rest, she resigned from her employment.
Salmone filed a claim for disability benefits under P.D. No. 626, as amended, with the Social Security System (SSS). The SSS denied her claim, a decision subsequently affirmed by the Employees’ Compensation Commission (ECC). The ECC ruled there was no substantial evidence proving her cardiovascular illness was work-connected or occupational. The Court of Appeals dismissed her petition, upholding the ECC’s finding that she failed to adduce proof satisfying the conditions for compensability of cardiovascular diseases.
ISSUE
Whether petitioner’s illness, atherosclerotic heart disease, atrial fibrillation, and cardiac arrhythmia, is compensable as a work-related disease under the Employees’ Compensation Law.
RULING
Yes, the illness is compensable. The Supreme Court reversed the decisions of the lower tribunals. Under the applicable law, for a non-listed illness to be compensable, the claimant must prove by substantial evidence that the risk of contracting the disease was increased by the working conditions. The Court clarified that cardiovascular diseases, which encompass the petitioner’s specific ailments, are listed as occupational diseases under ECC rules. Consequently, the degree of proof required is merely substantial evidence—such relevant evidence as a reasonable mind might accept as adequate.
The Court found that petitioner presented uncontroverted evidence that the severe chest pains manifested during her employment, directly linked to work-related stress, ultimately forcing her resignation. The law does not demand a direct causal relation but only a reasonable work-connection. Probability, not certainty, is the standard. The hypothesis of work-connection was deemed probable given the nature of her stressful job and the temporal connection between her work strain and the cardiac symptoms. Therefore, the SSS was ordered to pay her full disability benefits.