G.R. No. 159060; November 28, 2007
Gina Leviste, Petitioner, vs. Social Security System (Solid Mills, Inc.), Respondent.

FACTS

Petitioner Gina Leviste, widow of Ronald Leviste, filed a claim for death benefits under the Employees’ Compensation Law (P.D. No. 626). Ronald, a supervisor at Solid Mills, Inc., suffered “Sudden Cardiac Death” at 11:50 PM on September 9, 1999, after having completed his day shift at 4:00 PM and returning to his residence in Batangas. The SSS dismissed the claim, finding the death not work-related as it did not occur at the workplace, during the performance of official functions, or while executing an employer’s order. The Employees’ Compensation Commission (ECC) affirmed the dismissal, noting a lack of evidence that the decedent was subjected to strenuous work activities.
Petitioner elevated the case to the Court of Appeals, presenting new evidence that the nature of Ronald’s work involved constant exposure to fumes and heat. Crucially, she asserted that on his last day of work, Ronald performed an extremely strenuous activity: helping carry a 100-kilo air-conditioning compressor from a rooftop down several flights of stairs to a workshop 300 meters away. The CA dismissed the petition, prompting this appeal.

ISSUE

Whether the Court of Appeals erred in refusing to consider the death of Ronald Leviste as service-connected and compensable under the Employees’ Compensation Law.

RULING

Yes. The Supreme Court reversed the CA and granted the claim. The legal logic proceeds from ECC Resolution No. 432, which includes cardiovascular diseases in the List of Occupational and Compensable Diseases. This inclusion establishes a statutory presumption that such a disease is work-related, relieving the claimant of the burden to prove causal connection. However, this presumption only arises if the disease was contracted under specific working conditions outlined in the rules.
For cardiovascular diseases, the conditions include: (a) an acute exacerbation precipitated by unusual work strain in a person with a known heart condition; (b) work strain of sufficient severity followed within 24 hours by clinical signs of cardiac insult; or (c) the manifestation of persistent cardiac injury symptoms during work in a previously asymptomatic person. The Court found that the second and third conditions were satisfied. The employer’s own report cited “Cardiac Arrest Secondary to overfatigue.” Petitioner’s uncontroverted evidence detailed the severe physical strain of the decedent’s regular duties and the specific, extreme exertion on his final day of work. This strain, occurring within 24 hours of his death and in a person with no prior cardiac history, sufficiently triggered the statutory presumption that his sudden cardiac death was work-related and compensable. The CA erred in not applying this presumption to the established facts.