G.R. No. 174725, January 26, 2011
ALEXANDER B. GATUS, Petitioner, vs. SOCIAL SECURITY SYSTEM, Respondent.

FACTS

Petitioner Alexander B. Gatus worked at Central Azucarera de Tarlac from January 1, 1972, until his optional retirement on January 31, 2002, after 30 years of service. He was a covered SSS member. In August 1995, he was hospitalized and diagnosed with Coronary Artery Disease (CAD), Triple Vessel and Unstable Angina. His medical records indicated he had been hypertensive for 10 years and was a smoker. The SSS initially granted him Employees’ Compensation (EC) Permanent Partial Disability benefits. However, a 2003 SSS audit concluded his CAD was not work-related but was attributed to chronic smoking, and sought to recover the benefits paid. The SSS denied his protest and motion for reconsideration. The Employees’ Compensation Commission (ECC) denied his appeal on December 10, 2004, ruling that while CAD is listed as an occupational disease, petitioner failed to prove his employment conditions increased the risk of contracting it, noting smoking as a significant risk factor. The Court of Appeals affirmed the ECC’s decision. Petitioner contends his disease was caused by 30 years of exposure to harmful emissions (e.g., methane gas, diesel smoke containing carbon monoxide) at his workplace and that the smoking allegation was unproven.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in affirming the ECC’s finding that petitioner’s Coronary Artery Disease is not compensable under Presidential Decree No. 626, as amended.

RULING

The Supreme Court DENIED the petition, affirming the Court of Appeals’ decision. The Court held that for a sickness to be compensable under the law, it must either be a listed occupational disease with the conditions satisfied, or the claimant must prove by substantial evidence that the risk of contracting the disease was increased by the working conditions. While CAD (or Ischemic Heart Disease) is listed under Annex “A” of the Amended Rules, the claimant must still prove that the nature of his employment and its conditions increased the risk of contracting the disease. The Court found that petitioner failed to provide substantial evidence—such as scientific or medical data—to establish a causal link between his working conditions (exposure to alleged emissions) and his CAD. His allegations remained general and unsubstantiated. In contrast, the medical evidence indicated that atherosclerosis, the cause of his CAD, is primarily linked to risk factors like smoking, hypertension, and diet. The Court emphasized that awards cannot rest on speculation, and the findings of the ECC, being supported by evidence and affirmed by the Court of Appeals, are accorded respect and finality. The petition raised questions of fact, which are not reviewable in a petition for review on certiorari under Rule 45.