G.R. No. 187474; February 06, 2013
GOVERNMENT SERVICE INSURANCE SYSTEM, Petitioner, vs. MARILOU ALCARAZ, Respondent.

FACTS

Bernardo Alcaraz, employed for 29 years as a laborer and Metro Aide with the MMDA, was diagnosed with Pulmonary Tuberculosis and Community Acquired Pneumonia (CAP) in February 2004. He was hospitalized in May 2004 for Acute Diffuse Anterolateral Wall Myocardial Infarction, CAP, PTB, and Diabetes Mellitus Type 2. On January 15, 2005, he was found dead at his workplace. The autopsy concluded he died of Myocardial Infarction. His widow, Marilou, filed a claim for death benefits with the GSIS.
The GSIS denied the claim, asserting that the myocardial infarction was a complication of diabetes, a non-occupational disease, and thus not work-connected. The Employees’ Compensation Commission (ECC) affirmed the denial. On appeal, the Court of Appeals reversed the ECC, finding sufficient evidence of work-connection and ordering the GSIS to pay benefits. The GSIS filed this petition, arguing the CA erred in reversing the factual findings of the GSIS and ECC.

ISSUE

Whether the Court of Appeals erred in ruling that Bernardo Alcaraz’s myocardial infarction, which caused his death, was compensable as a work-related illness.

RULING

The Supreme Court denied the GSIS petition and affirmed the CA decision. The legal logic centers on the application of the conditions for compensability of cardiovascular diseases under the Amended Rules on Employees’ Compensation. While myocardial infarction is not a listed occupational disease, it can be compensable if substantial evidence shows the work conditions increased the risk of its occurrence or aggravated its development.
The Court found that Bernardo’s work as a laborer and Metro Aide, involving physical strain and stress, constituted the “unusual strain” required by the rules. Critically, the Court noted he had a pre-existing compensable illness, Community Acquired Pneumonia (CAP). Medical literature indicates CAP is a risk factor for acute myocardial infarction. Therefore, his work conditions and the compensable CAP substantially contributed to the fatal heart attack. The GSIS erroneously attributed the cause solely to diabetes, ignoring the aggravation from his work and other compensable conditions. The Court emphasized that in line with the constitutional policy of social justice and maximum aid to labor, the implementing agencies should adopt a liberal attitude in favor of employees when there is a basis for inferring a work-connection. The CA correctly applied this principle in awarding benefits.