G.R. No. L-46151 April 30, 1980
Lourdes L. Fetalvero, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Philippine Constabulary), respondents.

FACTS

Petitioner Lourdes L. Fetalvero sought death benefits under the New Labor Code following the demise of her husband, F/Sgt. Marcelino Q. Fetalvero, a member of the Philippine Constabulary. The deceased soldier served continuously from 1951 until his death on March 17, 1975, attaining the rank of First Sergeant. His duties involved being in charge of supplies and maintenance for company vehicles, which required him to report “day and night as per military order.” On the date of his death, he suffered a stroke, was rendered unconscious, and subsequently died at a military hospital. The attending physician certified the cause of death as cardio-pulmonary arrest, cerebral vascular accident (CVA), probably due to cerebral hemorrhage and hypertension.
The Government Service Insurance System (GSIS) denied the claim, reasoning that cardio-pulmonary arrest was not listed as an occupational disease nor proven to be caused by the nature of his employment. The Employees’ Compensation Commission (ECC) affirmed this denial, leading to the petition for review before the Supreme Court.

ISSUE

Whether the death of F/Sgt. Marcelino Q. Fetalvero, due to cardio-pulmonary arrest/CVA/hypertension, is compensable under the employees’ compensation law despite not being a listed occupational disease.

RULING

The Supreme Court granted the petition and reversed the ECC decision, awarding death benefits. The Court’s legal logic centered on the principle that compensability is not strictly limited to listed occupational diseases under the rules. The pivotal factor is whether the illness supervened during employment and was directly caused or aggravated by the nature of the work. The Court found that the deceased’s demanding duties, requiring constant availability day and night, created significant tension and strain. This work-related stress was a direct contributing factor to the fatal cardio-pulmonary arrest.
The Court reinforced this reasoning by citing its recent jurisprudence. In Mitra vs. ECC, it held that cardiovascular arrest caused by work-related tension is compensable, irrespective of its absence from the official list. Similarly, in Macatol vs. WCC, compensation was granted for a CVA that supervened during employment. Applying these precedents, the Court concluded that the deceased’s hypertension and subsequent fatal attack were directly induced by the pressures of his military duties. Therefore, the claim was compensable, and the GSIS was ordered to pay the petitioner death compensation, burial expenses, and attorney’s fees.