GR 149256; (July, 2006) (Digest)
G.R. No. 149256 ; July 21, 2006
ADELAIDA B. AQUINO, petitioner, vs. SOCIAL SECURITY SYSTEM and U.S. NAVAL COMMISSARY STORE, Subic Bay, respondents.
FACTS
Petitioner Adelaida Aquino sought death benefits under Presidential Decree No. 626 (the Employees Compensation Act) following the death of her husband, Jaime Aquino, from congestive heart failure on February 2, 2000. Jaime had worked as a grocery man at the US Naval Commissary Store in Subic Bay from 1970 until his separation in 1977. His duties included checking stock, shelving items, conducting inventories, and operating a forklift. The Social Security System (SSS) denied the claim, a decision affirmed by the Employees Compensation Commission (ECC), which found no causal link between the cause of death and his former employment, especially given his separation 23 years prior. The Court of Appeals subsequently dismissed petitioner’s appeal.
ISSUE
Whether the death of Jaime Aquino due to congestive heart failure is compensable under PD 626.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ decision. For an illness to be compensable under PD 626, it must either be listed as an occupational disease by the ECC or the claimant must prove through substantial evidence that the risk of contracting the illness was increased by the employee’s working conditions. Congestive heart failure is not listed as an occupational disease. Petitioner failed to present evidence establishing a reasonable causal connection between Jaime’s work as a grocery man and his eventual heart failure, or that his working conditions aggravated the risk of contracting the ailment.
Furthermore, even if considered under the rules for cardiovascular diseases (ECC Resolution No. 432), the claim fails as there was no proof of an acute exacerbation clearly precipitated by unusual work strain occurring within 24 hours of clinical signs, nor any showing of symptoms persisting during work performance. Critically, the 23-year interval between Jaime’s separation and his death created a “gaping hole” in petitioner’s claim, during which other intervening factors could have caused his death, imposing a greater burden of proof on petitioner which she did not discharge. The Court also accorded respect to the factual findings of the specialized administrative agencies and emphasized the need to balance social justice with the stability of the compensation trust fund.