The Supreme Court has clarified the requirements for compensation claims related to cardiovascular diseases, ruling that claimants need only demonstrate that their employment contributed even in a small degree to the development of the disease. This decision emphasizes a more lenient approach in favor of employees, aligning with the constitutional guarantee of social justice. It highlights that the existing employment need not be the only factor that causes the disease but that the employment contributed to its development.

From Public Service to Personal Loss: Establishing Work-Related Causation in Employee Compensation

This case revolves around Julieta Verzonilla’s claim for employee compensation following the death of her husband, Reynaldo, a Special Operations Officer (SOO) III in Quezon City. Reynaldo passed away due to cardiopulmonary arrest shortly after attending a demanding training seminar. The Employees’ Compensation Commission (ECC) denied Julieta’s claim, stating that she failed to prove a direct link between Reynaldo’s work and his cause of death. The central legal question is whether the conditions of Reynaldo’s employment, specifically the stress and physical demands, contributed to his fatal heart condition, making his death compensable under Philippine labor laws.

The Supreme Court, in its resolution, addressed the core issue of compensability under the Employees’ Compensation Law, specifically concerning cardiovascular diseases. The Court referenced Article 165 of the Labor Code, as amended by Presidential Decree (PD) 626, which defines sickness as either an occupational disease listed by the Employees’ Compensation Commission (ECC) or any illness caused by employment, provided that the risk of contracting the same is increased by working conditions. This provision sets the stage for understanding how illnesses are considered work-related and thus compensable.

Building on this legal foundation, the Court examined the Amended Rules on Employees’ Compensation, which operationalize PD 626. These rules stipulate that for a sickness resulting in disability or death to be compensable, it must either be an occupational disease listed under Annex “A” of the rules, with the conditions specified therein met, or proof must be presented demonstrating that the risk of contracting the disease was increased by the working conditions. This framework establishes a dual-pathway for compensation: either direct inclusion in the list of occupational diseases or demonstration of increased risk due to work conditions.

The Court then turned its attention to Annex “A” of the Amended Rules, which explicitly lists cardiovascular diseases as occupational and work-related, albeit under specific conditions. These conditions include instances where a pre-existing heart condition is exacerbated by unusual work strain, where the strain of work leads to an acute cardiac attack within 24 hours, or where symptoms of cardiac impairment manifest during work performance. The presence of these conditions is critical in determining whether a cardiovascular disease can be linked to employment for compensation purposes.

However, the Court emphasized a pivotal shift in the legal landscape concerning workmen’s compensation. Previously, under Act No. 3428, a presumption of compensability existed, meaning that any injury or disease arising from employment was presumed compensable. PD 626, however, abandoned this presumption, placing the burden of proof on the claimant to demonstrate, through substantial evidence, that the conditions for compensability are met. This change underscores the importance of presenting concrete evidence to support claims for work-related illnesses.

Analyzing the specifics of Julieta’s claim, the Court noted that while cardiovascular disease is listed as an occupational disease, this does not automatically guarantee compensation. Julieta was required to provide substantial evidence that any of the conditions outlined in item number 18 of the Amended Rules on Employees Compensation (EC) were satisfied or that Reynaldo’s risk of contracting his disease was increased by his working conditions. This aspect of the ruling clarifies that listing a disease as occupational does not negate the need for demonstrating a clear connection between the work and the disease.

Julieta argued that Reynaldo’s pre-existing hypertension and the abdominal pain he experienced were aggravated by the demanding conditions of his job as SOO III, ultimately leading to his death. The Court found Julieta’s claim persuasive, especially under paragraph (b) of item 18, which addresses situations where the strain of work is severe enough to cause a cardiac event within 24 hours. The Court acknowledged that Reynaldo’s series of strenuous activities immediately preceding his heart attack, coupled with the fact that his cardiac arrest and subsequent death occurred within 24 hours of such strain, satisfied the criteria under paragraph (b).

The Court also considered evidence that Reynaldo’s pre-existing heart condition was exacerbated by the stresses of his work. His duties included conducting and attending training seminars, performing hazard assessments, and engaging in extensive fieldwork, all of which required stressful and extended travel hours. The fact that Reynaldo died while attending a seminar in Tagaytay City, after a day of lectures, fieldwork, and travel, underscored the continuous exposure to job-related stresses that contributed to his death. This aspect of the ruling highlights that even indirect work-related stresses can be significant in determining compensability.

Furthermore, the Court emphasized that employment need not be the sole factor contributing to the development of an illness for it to be compensable. It is sufficient that the employment contributed even in a small degree to the development of the disease. The standard of proof required to establish this work connection is merely substantial evidence, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. In this context, the Court referenced its previous ruling in GSIS v. Capacite, reiterating that a reasonable work-connection, not a direct causal relation, is sufficient. This reiteration reinforces the principle that even a minimal work-related contribution to the illness is enough to warrant compensation.

Drawing from these considerations, the Court concluded that Julieta had presented substantial evidence supporting her claim for compensation benefits related to her late husband’s death. The Court also reiterated the constitutional guarantee of social justice towards labor, which mandates a liberal approach in favor of the employee when deciding claims for compensability. This perspective remains pertinent despite PD 626’s abandonment of the presumption of compensability. The Court reinforced that the existing law continues to be an employee’s compensation law and social legislation; therefore, the leniency of the law in favor of the working class still prevails. The Court said:

Presidential Decree No. 626, as amended, is said to have abandoned the presumption of compensability and the theory of aggravation prevalent under the Workmens Compensation Act. Despite such abandonment, however, the present law has not ceased to be an employees’ compensation law or a social legislation; hence, the liberality of the law in favor of the working man and woman still prevails, and the official agency charged by law to implement the constitutional guarantee of social justice should adopt a liberal attitude in favor of the employee in deciding claims for compensability, especially in light of the compassionate policy towards labor which the 1987 Constitution vivifies and enhances.

This perspective underscores the judiciary’s commitment to upholding the rights and welfare of workers, ensuring that the legal system remains responsive to their needs in cases of work-related illnesses and injuries.

FAQs

What was the key issue in this case?	The key issue was whether the death of Reynaldo Verzonilla, due to cardiopulmonary arrest, was compensable under the Employees’ Compensation Law, considering his work as a Special Operations Officer and his pre-existing hypertension.
What did the Employees’ Compensation Commission (ECC) initially decide?	The ECC initially affirmed the GSIS’s denial of Julieta’s claim, stating that she failed to prove a substantial connection between Reynaldo’s death and his work conditions, or that his work increased the risk of contracting his ailment.
What is required for a cardiovascular disease to be considered compensable?	For cardiovascular diseases to be compensable, the claimant must show that either a pre-existing heart disease was exacerbated by unusual work strain, the strain of work caused a cardiac attack within 24 hours, or symptoms of cardiac impairment manifested during work.
What standard of proof is required in employee compensation claims?	The standard of proof required is substantial evidence, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, indicating a reasonable work-connection rather than a direct causal relation.
Did the Supreme Court find a sufficient connection between Reynaldo’s work and his death?	Yes, the Supreme Court found that the strenuous activities Reynaldo underwent prior to his heart attack, combined with his pre-existing heart condition, provided substantial evidence of a work-related connection to his death.
Does the employment need to be the sole factor in the illness for it to be compensable?	No, the employment does not need to be the sole factor; it is sufficient that the employment contributed even in a small degree to the development of the disease.
What is the significance of social justice in deciding compensation claims?	The constitutional guarantee of social justice towards labor demands a liberal attitude in favor of the employee when deciding claims for compensability, reflecting a compassionate policy towards labor.
What was the Supreme Court’s final ruling?	The Supreme Court granted the petition, reversing the Court of Appeals’ decision and ordering the Employees’ Compensation Commission to award death benefits to Julieta in relation to the death of Reynaldo Verzonilla.

In conclusion, the Supreme Court’s decision in this case clarifies and eases the requirements for compensation claims related to work-related illnesses, particularly cardiovascular diseases. By emphasizing that even a small contribution from employment to the development of a disease is sufficient for compensability, the Court reinforces the social justice mandate to protect the working class.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: JULIETA T. VERZONILLA vs. EMPLOYEES’ COMPENSATION COMMISSION, G.R. No. 232888, August 14, 2019