Cortes v. Employees' Compensation Commission
REITERATIONFacts
1. The Antecedents: Atty. Querubin B. Cortes, Clerk of Court of the Aklan Court of First Instance, suffered from various ailments including dizziness, frequent urination, general body weakness, shortness of breath, chest pain, and susceptibility to fatigue from 1954 onwards. Despite his deteriorating health, he continued to report for work. He was hospitalized in September 1975, where his conditions were diagnosed as hypertensive cardiovascular disease, cardiomegaly, diabetes mellitus, and pneumonitis. He was readmitted in October 1975 with severe symptoms and ultimately died on October 24, 1975, from myocardial infarction and liver deterioration. 2. Procedural History: The widow, Ester C. Cortes, filed a claim for workmen's compensation, which was denied by the Government Service Insurance System (GSIS) on August 23, 1976, on the grounds that acute myocardial infarction was not an occupational disease under the New Labor Code. This denial was affirmed by the Employees' Compensation Commission (ECC) on October 26, 1976. The petitioner then filed a petition for review on certiorari with the Supreme Court. 3. The Petition: The petitioner seeks to set aside the decision of the ECC. While the case was pending, the ECC issued Resolution No. 432 on July 20, 1977, adding cardiovascular disease to the list of work-related illnesses. Subsequently, on September 7, 1978, the ECC issued Resolution No. 1071, approving payment of the claim filed by the petitioner. In light of these developments, the Solicitor General filed a motion to dismiss the petition, arguing that the case had become moot and academic. The Supreme Court, in agreement with this motion, dismissed the petition.
Issue(s)
Whether the claim for workmen's compensation for the death of Atty. Querubin B. Cortes due to myocardial infarction is compensable. Whether the petition has become moot and academic.
Ruling
The petition is dismissed for having become moot and academic. The Employees' Compensation Commission (ECC) issued Resolution No. 1071 on September 7, 1978, approving the payment of the claim filed by the petitioner, consistent with the liberal construction of social legislation in favor of employees and their dependents.
Ratio Decidendi
On Whether the claim for workmen's compensation for the death of Atty. Querubin B. Cortes due to myocardial infarction is compensable: The respondent Commission initially denied the claim, citing medical studies indicating that myocardial infarction is caused by factors unrelated to employment, such as coronary atherosclerosis, hypercholesterolemia, hypertension, cigarette smoking, diabetes mellitus, obesity, sedentary living, and psychosocial tensions. However, subsequent developments led to a change in the ECC's stance. On July 20, 1977, ECC Resolution No. 432 was approved, incorporating an additional list of seven illnesses, including cardiovascular disease, into the official list of work-related diseases under PD 626, as amended. Furthermore, in a special meeting on January 13, 1978, the ECC, with the Solicitor General present, agreed to recommend payment and seek dismissal of appealed ECC cases that became compensable due to ECC Resolution No. 432 and recent ECC rulings. Although the present case was appealed in January 1978 and thus not initially included in the list of cases subject to the January 13, 1978 agreement, the ECC, after restudying the case and consistent with the steps taken in similar cases, issued Resolution No. 1071 on September 7, 1978, approving payment of the petitioner's claim. On Whether the petition has become moot and academic: The petition has become moot and academic due to the subsequent action taken by the Employees' Compensation Commission (ECC). The ECC, recognizing the evolving interpretation of work-related diseases and the spirit of social legislation, issued Resolution No. 1071 on September 7, 1978, approving the payment of the claim filed by the petitioner. This action by the government agency responsible for administering compensation claims renders the judicial review of the original denial unnecessary and moot. The Court emphasized that the Workmen's Compensation Act is a social legislation designed to give relief to the workman and should be construed fairly, reasonably, and liberally in favor of and for the benefit of the employee and his dependents, a principle that the ECC's subsequent resolution evidently embraced.
Main Doctrine
The Workmen's Compensation Act is a social legislation intended to provide relief to employees and their dependents, and as such, it should be interpreted and applied liberally in their favor. This principle is particularly relevant when the Employees' Compensation Commission (ECC) itself takes steps to approve a claim, even after an initial denial, due to evolving interpretations or new resolutions concerning work-related illnesses.