G.R. No. 225827, July 28, 2021
Social Security System, Petitioner, vs. Belinda C. Cuento, Respondent.

FACTS

Respondent Belinda C. Cuento’s husband, Maximo M. Cuento, was employed as a motorized messenger by Gold Rush Services, Corp., assigned at Metro Bank. His last contract was in February 2011 until his death on October 4, 2011. On June 15, 2011, Maximo was diagnosed with a transient ischemic attack. While on duty on October 4, 2011, he suffered a stroke, was brought to San Juan De Dios Hospital, and was declared “dead on arrival.” The Post Mortem Death Certificate listed the cause of death as myocardial infarction. Respondent filed a claim for death benefits with the SSS, which was denied. The denial was sustained by the SSS-Medical Operations Department and later affirmed by the Employees’ Compensation Commission (ECC). The ECC ruled there was no showing that Maximo had been subjected to unusual strain at work when he suffered the stroke, and that atherosclerosis caused the myocardial infarction. Respondent appealed to the Court of Appeals (CA), which reversed the ECC decision. The CA found that Maximo’s duties as a messenger, requiring him to drive around Metro Manila and be exposed to heat, rain, and pollution, constituted strenuous work that aggravated his condition. The CA noted Maximo was already at risk after his transient ischemic attack and found the myocardial infarction work-connected. The SSS filed the present petition.

ISSUE

Whether Maximo’s myocardial infarction is a compensable disease under Presidential Decree No. 626, as amended.

RULING

The petition is without merit. The Supreme Court affirmed the CA Decision, holding the death compensable. Myocardial infarction is a cardiovascular disease. Under ECC Board Resolution No. 11-05-13, cardiovascular disease is deemed a compensable occupational disease if, among other conditions, “the strain of work that brings about an acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship.” This condition was met, as Maximo suffered loss of consciousness while on duty and died within 24 hours due to myocardial infarction. His duties as a motorized messenger involved daily exposure to heat, rain, and pollution, and the stress and strain of driving around Metro Manila. The Court cited Rañises v. Employees Compensation Commission, which ruled that a driver/messenger’s ailment, due to severe strain, fatigue, and traffic stress, is work-connected and compensable. The conditions for compensability were satisfied: (1) the work involved risks (heat, rain, pollution); (2) the stress and strain of the job were major factors causing death; (3) prolonged exposure to these conditions contributed to the death. The Court emphasized that agencies like the ECC and SSS should adopt a liberal attitude in favor of employees in deciding claims for compensability, especially where there is a basis for inferring a work-connection. The SSS was ordered to pay the proper death benefits.