Case Digest: GSIS v. Alcaraz

G.R. No. 187474 : February 6, 2013




Bernardo was employed by the Metro Manila Development Authority in Makati City as laborer, Metro Aide and Metro Aide I for almost twenty-nine years.

Sometime in February 2004, Bernardo was diagnosed with Pulmonary Tuberculosis (PTB) and Community Acquired Pneumonia (CAP). On May 13, 2004, he was confined at the Ospital ng Makati. He was discharged on May 19, 2004 with the following diagnosis: Acute Diffuse Anterolateral Wall Myocardial Infarction, Killips IV-1, CAP High Risk, PTB III and Diabetes Mellitus Type 2.

On January 15, 2005, Bernardo was found dead at the basement of the MMDA building. It was found in the autopsy that Bernardo died of Myocardial Infarction, old and recent. Bernardos widow, Marilou, subsequently filed a claim for death benefits with the Govenment Service Insurance System (GSIS).

The GSIS denied the claim for death benefits on the ground that myocardial infarction, the cause of Bernardos death, was directly related to diabetes which is not considered a work-connected illness; hence, its complications, such as myocardial infarction, are not work-related.

Marilou appealed to the ECC which affirmed the GSIS ruling. Aggrieved, she sought relief from the CA through a petition for review under Rule 43 of the Rules of Court, contending that (1) the ECC misappreciated the facts. She argued that even if the underlying cause of Bernardos death was diabetes, the illness was acquired in the course of his employment and was further aggravated by the nature of his work; and (2) the ECC gravely abused its discretion for giving scant consideration to the medical findings on Bernardos true condition prior to his death.

The GSIS, on the other hand, prayed that the petition be denied, contending that in the absence of satisfactory evidence that Bernardos nature of employment predisposed him to contract the ailment, the widows claim must fail.

The CA granted the petition and set aside the ECC ruling. It opined that while myocardial infarction is not among the occupational diseases listed under Annex A of the Amended Rules on Employees Compensation, the ECC, pursuant to Resolution No. 432, laid down conditions under which cardio-vascular diseases can be considered as work-related and therefore compensable.

The CA found sufficient proof of work-connection between Bernardos ailment and his working conditions. It believed that his work as laborer and metro aide must have substantially contributed to his illness.

GSIS moved for reconsideration but was denied by the CA.

Hence, this petition.


Whether or not Bernardos illness was work-related and/or the risk of contracting the illness was increased by the nature of his work?


The petition is denied.


The GSIS and the ECC denied the claim of his widow for death benefits on the ground that his death was due to myocardial infarction which they declared to be non-compensable; that it is not work-related as it is simply a complication of diabetes mellitus; and that diabetes mellitus is not in the list of occupational diseases and, for this reason, its complications such as myocardial infarction, are not work-related.

The conclusions of the two agencies totally disregarded the stressful and strenuous conditions under which Bernardo toiled for almost 29 long years as a laborer and as a metro aide. By so doing, they closed the door to other influences that caused or contributed to Bernardos fatal heart problem an ailment aggravated with the passage of time by the risks present in the difficult working conditions that Bernardo had to bear from day to day in his employment.

While diabetes mellitus was indeed a complicating factor in Bernardos health condition and indisputably aggravated his heart problem, we cannot discount other employment factors, mental and physical, that had been indisputably present; they contributed, if not as a direct cause of the heart condition itself, as aggravation that worsened and hastened his fatal myocardial infarction.

For instance, it is undisputed that Bernardo was earlier diagnosed with CAP which could also be a predisposing factor to myocardial infarction. There is also stress due to the nature of Bernardos work.

Myocardial infarction, also known as coronary occlusion or just a coronary, is a life threatening condition. Predisposing factors for myocardial infarction are the same for all forms of Coronary Artery Disease, and these factors include stress. Stress appears to be associated with elevated blood pressure. (Government Service Insurance System (GSIS) v. Cuanang, G.R. No. 158846)

The CA, therefore, is correct in holding that there is substantial evidence supporting the conclusion that myocardial infarction in Bernardos case is work related.


The CAs conclusion is bolstered by the fact that the ECC itself, the government agency tasked by law to implement the employees compensation program

Included cardio-vascular diseases in the list of occupational diseases, making them compensable, subject to any of the conditions stated in its enabling Resolution No. 432.With the resolution, it should be obvious that by itself, a heart disease, such as myocardial infarction, can be considered work-related, with or without the complicating factors of other non-occupational illnesses. Thus, the Court so ruled in Rases v. ECC (504 Phil. 340, 345 (2005)) where it emphasized that the incidence of acute myocardial infarction, whether or not associated with a non-listed ailment, is enough basis for compensation.

Resolution No. 432 provides (as one of the conditions) that a heart disease is compensable if it was known to have been present during employment, there must be proof that an acute exacerbation was clearly precipitated by the unusual strain by reason of the nature of his work. Based on the evidence on record, we find as the CA did, that the nature of Bernardos duties and the conditions under which he worked were such as to eventually cause the onset of his myocardial infarction. The stresses, the strain, and the exposure to street pollution and to the elements that Bernardo had to bear for almost 29 years all to real too be ignored. They cannot but lead to a deterioration of health particularly with the contributing factors of diabetes and pulmonary disease.