G.R. No. 158846 ; June 3, 2004
GOVERNMENT SERVICE INSURANCE SYSTEM (GSIS), petitioner, vs. TEODOSIO CUANANG, represented by MARC DENNIS CUANANG, respondent.

FACTS

Carmen T. Cuanang, a public school teacher, retired in November 1998 after nearly 26 years of service. During her employment, she was hospitalized for Bronchial Asthma, Pneumonia, and Rheumatic Heart Disease. The GSIS granted her temporary and later permanent partial disability benefits. Carmen died on May 7, 2000, at age 65. Her death certificate listed Cardio Pulmonary Arrest due to Acute Myocardial Infarction as the immediate cause, with Bronchial Asthma and Hypertension as underlying causes. Her husband, respondent Teodosio Cuanang, filed a claim for death benefits under Presidential Decree No. 626 (the Employees’ Compensation Act).
The GSIS denied the claim, stating that Acute Myocardial Infarction was not compensable as it occurred after retirement and beyond the period of her permanent partial disability award. The Employees’ Compensation Commission (ECC) affirmed the denial, reasoning that the ailments were not work-connected, with Hypertension developing post-retirement. The Court of Appeals reversed the ECC, finding substantial evidence for compensability and ordering GSIS to pay the death benefits.

ISSUE

Whether the death of Carmen Cuanang is compensable under Presidential Decree No. 626, as amended, notwithstanding that it occurred after her retirement.

RULING

Yes, the death is compensable. The Supreme Court affirmed the Court of Appeals. The legal logic centers on the established principle that a claim for death benefits cannot be defeated by the mere fact of separation from service. The Court applied its ruling in Consorcia F. Manuzon v. Employees’ Compensation Commission, where death from myocardial infarction occurring four and a half years after retirement was deemed compensable because the work-related heart disease originated during employment and caused the retirement due to disability.
Here, Carmen Cuanang died less than a year after retiring due to heart disease and related conditions. If a death nearly five years post-retirement is covered, with more reason should a death within one year be compensable. The required degree of proof under PD 626 is merely substantial evidence, meaning such relevant evidence as a reasonable mind might accept to support a conclusion. The Court found this standard met, as the hypothesis of a work connection between her teaching profession and the development of her fatal cardiovascular conditions was probable. The conditions that led to her death were present and documented during her employment, establishing a reasonable work connection.