G.R. No. 88573 June 25, 1990
Consorcia F. Manuzon, petitioner, vs. Employees’ Compensation Commission and Government Service Insurance System (Mindanao State University MSU, Marawi City), respondents.

FACTS

Petitioner Consorcia Manuzon sought death benefits under Presidential Decree No. 626, as amended, following the death of her husband, Assistant Professor Jose Manuzon. During his employment at Mindanao State University, Jose suffered a cardio-vascular accident (CVA) or stroke in October 1982, diagnosed as hemiparesis post-CVA thrombosis, which rendered him permanently and totally disabled. He was forced to retire effective January 22, 1983, and received permanent total disability (PTD) benefits from the GSIS. He died on June 17, 1987, approximately four and a half years after retirement, due to acute myocardial infarction.
The GSIS denied petitioner’s claim for continued pension and death benefits, stating the death was not compensable as it occurred long after retirement, terminating the employer-employee relationship. The GSIS only paid the remaining balance of the five-year guaranteed PTD period. The Employees’ Compensation Commission (ECC) affirmed the denial, ruling that the myocardial infarction was a different illness from the earlier CVA, occurred post-retirement, and failed to satisfy the specific conditions for compensability of heart disease under the ECC rules.

ISSUE

Whether the primary beneficiaries of a covered employee, who was forced to retire due to a work-connected permanent total disability and later died of a related ailment, are entitled to death benefits under Article 194(b) of P.D. No. 626, as amended.

RULING

Yes. The Supreme Court reversed the decisions of the GSIS and ECC, granting death benefits to the petitioner. The Court applied the rule of liberal interpretation in favor of the employee in social legislation. While a “covered employee” typically refers to one in active service, the implementing rules extend death benefits to a “permanently totally disabled pensioner.”
The legal logic centered on the causal connection between the work-connected disability and the subsequent cause of death. The Court found that the deceased’s initial CVA (a cardio-vascular accident causing paralysis) and his fatal myocardial infarction (another cardio-vascular event) were closely related ailments, both stemming from heart disease. This disease developed during his employment as a professor, a strain-inducing occupation that contributed to its work-oriented nature. The fact that the fatal attack occurred years after retirement did not sever this causal link. The cause of his compulsory retirement (CVA) and the cause of his death (myocardial infarction) were substantively the same work-connected disease process. Therefore, his death was compensable. The Court directed the grant of death benefits, dependents’ pension for minor children, and funeral benefits.