G.R. No. 232888. August 14, 2019.
JULIETA T. VERZONILLA, PETITIONER, VS. EMPLOYEES’ COMPENSATION COMMISSION, RESPONDENT.

FACTS

Reynaldo Verzonilla was a Special Operations Officer III for the Quezon City Department of Public Order and Safety from 1999 until his death in 2012. His duties involved disaster preparedness, fieldwork, and attending numerous seminars and trainings. In July 2012, he attended a training in Tagaytay City on the Rapid Earthquake Damage Assessment System software. On July 5, 2012, he died due to “cardio pulmonary arrest, etiology undetermined” after complaining of abdominal and chest pain. He had a known history of hypertension since 2002.
His widow, Julieta, filed a claim for death benefits under Presidential Decree No. 626. The Government Service Insurance System (GSIS) denied the claim, finding no evidence that Reynaldo’s ailment was work-connected or that his duties increased the risk of contracting it. The Employees’ Compensation Commission (ECC) affirmed the denial, ruling that the claimant failed to satisfy the specific conditions for cardiovascular diseases listed as occupational diseases or to prove that work conditions increased the risk. The Court of Appeals upheld the ECC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming the denial of Julieta Verzonilla’s claim for employees’ compensation benefits arising from her husband’s death.

RULING

The Supreme Court granted the petition and reversed the assailed rulings. The legal framework under PD 626, as amended, provides two alternative paths for compensability: (1) the sickness is a listed occupational disease with its conditions satisfied, or (2) if not listed, proof that the risk of contracting the disease was increased by the working conditions. Cardiovascular disease is a listed occupational disease under Annex “A” of the Amended Rules, compensable if conditions like an acute exacerbation precipitated by unusual work strain are met.
The Court found that the nature of Reynaldo’s work as a disaster operations officer, which involved constant fieldwork, coordination, and successive trainings—including one away from his station immediately preceding his death—involved unusual strain beyond his regular routine. This constituted the “unusual strain” required by the conditions for cardiovascular diseases. The Court emphasized that in employees’ compensation, which is social legislation, strict rules of evidence are relaxed; probability, not certainty, is the standard. The chronological proximity between his strenuous work activities and his fatal cardiac arrest established a reasonable work-connection. Thus, the claim was compensable under the first path of listed occupational diseases, and the denial was erroneous.