Case Analysis

1244 words - 5 pages

CASE ANALYSIS

PART I
G.R. No. 170743
Date: April 12, 2007

PART II
Petitioner: GOVERNMENT SERVICEINSURANCE SYSTEM
Respodent: LUCITA R. VILLAREAL
Nature of the case: Civil case

PART III
Facts of the case:
Respondent is the widow of Zacarias F. Villareal, a technical education and skills development supervisor in the Technical Education and Skills Development Authority at the time of his death on October 20, 2002 due to myocardial infarction.

Respondent filed with petitioner a claim for death benefits under PD 626, as amended. Petitioner denied the claim on the ground that the cause of death was not work-connected. The ECC upheld petitioner. On appeal, however, the CA ...view middle of the document...

(c) If a person who was apparently asymptomatic before subjecting himself to strain at work showed signs and symptoms of cardiac injury during the performance of his work and such symptoms and signs persisted, it is reasonable to claim a causal relationship.

The CA found that “[t]he various stressful tasks and responsibilities the deceased had to perform exacerbated the development of his illness.” It held that Zacarias’ case was covered by condition (a) of Resolution No. 432.

In several cases, we ruled consistently that myocardial infarction is a compensable occupational disease. In Rañises v. ECC, we summarized some of these cases:

In Sepulveda v. Employees Compensation Commission, a public school teacher, assigned to a remote rural area, died of myocardial infarction. In sustaining the claim for compensation benefits, we held that due to his occupation as a school teacher assigned to one of the remotest parts of Tangub City, his illness was directly brought about by his employment or was a result of the nature of such employment.

In Cortes v. Employees Compensation Commission, we ruled that myocardial infarction is now considered an occupational disease by the ECC and is, therefore, compensable.

Then in Eastern Shipping Lines, Inc. v. Philippine Overseas Employment Administration, we upheld the ruling of the POEA awarding compensation benefits to the heirs of a Filipino seaman who died of myocardial infarction while his vessel was in Japan.

In Roldan v. Republic, we held that a poor schoolteacher who gave the best years of her life in the service and who in the process, contracted heart ailment and hypertension, is entitled to compensatory benefits corresponding to her claim.

In Tibulan v. Inciong, a barge captain died of myocardial infarction. We held that where an employee had entered employment in good health and suffered an illness in the course of an employment which he never had before, he has in his favor the statutory presumption that his illness or disease is compensable. We reiterated our ruling in the Heirs of the Late R/O Reynaldo Aniban v. National Labor Relations Commission. In this case, a ship radio operator, who was healthy when he boarded his vessel, died of myocardial infarction three months later. We ruled that his disease is compensable on the ground that any kind of work or labor produces stress and strain normally resulting in wear and tear of the human body.

In Government Service Insurance System v. Gabriel, we ruled that acute myocardial infarction is listed as an occupational disease, and its incidence, whether or not associated with a non-listed ailment, is enough basis for requiring compensation. And in Republic v. Mariano, we reiterated our ruling in...

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