GR 157038; (December, 2009) (Digest)
G.R. No. 157038, December 23, 2009
Government Service Insurance System, Petitioner, vs. Jean E. Raoet, Respondent.
FACTS
The respondent, Jean E. Raoet, filed a claim for death benefits under Presidential Decree No. 626, as amended, following the death of her husband, Francisco M. Raoet, on May 5, 2001. Francisco was an Engineer A at the National Irrigation Administration (NIA). His death certificate listed the causes as: Immediate cause: Cardiac Arrest; Antecedent cause: Acute Massive Hemorrhage; Underlying cause: T/C Bleeding Peptic Ulcer Disease. The GSIS denied the claim, citing a lack of supporting documents to prove the peptic ulcer was work-related, a decision affirmed by the Employees’ Compensation Commission (ECC). The Court of Appeals (CA) reversed the ECC, ruling the death was compensable because the immediate cause was cardiac arrest. The GSIS filed the present petition, arguing that peptic ulcer is not a listed occupational disease and no proof was shown that the risk of contracting it was increased by Francisco’s working conditions.
ISSUE
Whether the death of Francisco M. Raoet, with peptic ulcer as the underlying cause, is compensable under the employees’ compensation law.
RULING
Yes, the death is compensable. The Supreme Court denied the GSIS petition. The Court held that a duly-registered death certificate is prima facie evidence of the facts stated therein, including the cause of death. Since neither the GSIS nor the ECC presented evidence to refute the death certificate, it is established that peptic ulcer was the underlying cause. Contrary to the CA’s reasoning, the compensability hinges on this underlying cause, not the immediate cause of cardiac arrest. Peptic ulcer is a compensable occupational disease under ECC Resolution No. 1676 (incorporated in Annex “A” of the Amended Rules), provided the occupation involves prolonged emotional or physical stress. Francisco’s role as an Engineer A, involving supervision of construction and review of plans, constitutes an occupation with prolonged stress that satisfies the condition for compensability. The claim is granted.