G.R. No. 182297 , June 21, 2017
Government Service Insurance System vs. Fe L. Esteves

FACTS

Antonio Esteves, Sr., a utility worker at Gubat District Hospital, died on August 5, 2000. His death certificate listed the causes as: immediate cause hemorrhagic cerebrovascular accident (CVA or stroke); antecedent cause Stage III hypertension; and underlying cause Non-Insulin Dependent Diabetes Mellitus (NIDDM). His duties involved physically demanding tasks such as preparing beds, mopping, carrying patients, and running errands for medical staff. His widow, respondent Fe L. Esteves, filed a claim for death benefits under PD 626 (the Employees’ Compensation Act), believing his death was work-related.
Petitioner GSIS denied the claim, ruling that NIDDM, the underlying cause, was not an occupational disease and was not work-connected. The Employees’ Compensation Commission (ECC) affirmed the denial, stating that diabetes, caused by genetic factors and lifestyle, was the significant factor leading to hypertension and stroke, irrespective of his working conditions. The Court of Appeals reversed the ECC, finding that the deceased’s stressful and physical tasks contributed to his illness, making the death compensable.

ISSUE

Whether the death of Antonio Esteves, Sr., resulting from a hemorrhagic CVA complicated by hypertension and diabetes, is compensable under PD 626, as amended.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals and reinstating the ECC decision denying the claim. The legal logic hinges on the strict requirements for compensability under the law. For a sickness and resulting death to be compensable, the sickness must either be an occupational disease listed under the Amended Rules with all conditions satisfied, or the claimant must prove that the risk of contracting the disease was increased by the working conditions.
Here, the cause of death was a hemorrhagic CVA. For such a cardiovascular event to be compensable as an occupational disease, Annex “A” of the Amended Rules requires proof of, among other conditions, a history of trauma at work or evidence that hypertension caused impairment of specific body organs. The Court found the record bereft of any evidence showing the deceased suffered head trauma at work. Furthermore, no medical evidence established that his hypertension had caused impairment to organs like the kidneys, heart, or brain prior to his death. The Court emphasized that the mere physical nature of his job was insufficient to establish the required causal link. Since the claimant failed to prove that the risk of contracting the fatal CVA was increased by his employment, the death is not compensable under the law.