Fetalvero v. Employees' Compensation Commission
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns a claim for employee's compensation benefits filed by Lourdes Laviña Vda. de Fetalvero following the death of her husband, F/Sgt Marcelino Q. Fetalvero. F/Sgt Fetalvero served in the Philippine Constabulary from March 19, 1951, until his death on March 17, 1975. His attending physician diagnosed his illness and cause of death as cardio-pulmonary arrest, CVA, probably cerebral hemorrhage, and hypertension. The deceased was responsible for supplies and maintenance of company vehicles, a role that required him to report "day and night as per military order." 2. Procedural History: The petitioner, Lourdes Laviña Vda. de Fetalvero, filed an Income Benefits Claim with the Government Service Insurance System (GSIS) under the New Labor Code, asserting that her husband's illness was directly caused by his duties. The GSIS denied the claim on June 9, 1976, stating that the deceased's ailment was not an occupational disease or one caused by the nature of his employment. This decision was subsequently appealed to the Employees' Compensation Commission (ECC). The ECC affirmed the GSIS's decision, dismissing the petitioner's claim. 3. The Petition: This case comes before the Supreme Court on a petition for review on certiorari of the decision rendered by the Employees' Compensation Commission. The petitioner argues that the illness and death of her husband were directly caused by the nature of his work as a First Sergeant in the Philippine Constabulary, which involved demanding duties and irregular hours. The petition seeks to overturn the ECC's ruling, which found the ailment not to be an occupational disease and denied compensation, by asserting a direct causal link between the employment conditions and the fatal illness, referencing prior Supreme Court decisions that have allowed compensation for similar conditions.
Issue(s)
Whether the death of F/Sgt. Marcelino Q. Fetalvero due to cardio-pulmonary arrest, CVA, or hypertension is compensable under the New Labor Code. Whether the illness of the deceased was directly caused by the nature of his work as a First Sergeant of the Philippine Constabulary.
Ruling
The decision of the Employees' Compensation Commission is set aside. The Government Service Insurance System is ordered to pay the petitioner death compensation, burial expenses, and attorney's fees.
Ratio Decidendi
On whether the death is compensable: The Court held that there is no question that the illness of the deceased Marcelino Fetalvero supervened during his employment. The cause of his death is admittedly cardio-pulmonary arrest, CVA, or hypertension. The nature of his work as in-charge of supplies and maintenance of company vehicles required him to report "day and night as per military order." Therefore, his illness must have been directly caused by the nature of his work. The Court reiterated its ruling in Mitra vs. ECC, et al., stating that the argument that cardio-respiratory arrest is not listed as an occupational disease is of no moment, as the list of occupational diseases is not exhaustive and may be expanded. The crucial factor is whether the illness may be caused by tension arising from the performance of duty. In Macatol vs. WCC, et al., the Court ruled that an employee totally disabled by CVA Cerebral Hemorrhage which supervened during employment is entitled to maximum compensation. Thus, the illness is compensable. On whether the illness was directly caused by the nature of his work: The Court found that the deceased's duties as First Sergeant of the Philippine Constabulary, specifically being in charge of supplies and maintenance of company vehicles, required him to report "day and night as per military order." This demanding nature of his work, involving potential tension and irregular hours, directly contributed to his illness, cardio-pulmonary arrest, CVA, or hypertension. The attending physician's certification further supported this causal link. Therefore, the illness is deemed to have been directly caused by the nature of his work, making the claim compensable.
Main Doctrine
The illness of an employee, even if not listed as an occupational disease, is compensable if there is a direct causal link between the illness and the nature of the work, and the illness supervened during employment.