Salmone v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Dominga A. Salmone was employed for fourteen (14) years as an overall custodian and officer in charge of the sewing department of Paul Geneve Entertainment Corporation. In early 1996, she began experiencing chest pains, which became unbearable by April 1996, leading her to take a leave of absence. Medical examinations revealed she was suffering from Atherosclerotic heart disease, Atrial Fibrillation, and Cardiac Arrhythmia. Following her doctor's recommendation, she resigned from her work to rest and hopefully recover. Procedural History: Petitioner filed a claim for compensation benefits under P.D. No. 626, as amended, with the Social Security System (SSS). The SSS denied her claim. A motion for reconsideration was also denied. Petitioner appealed to the Employees' Compensation Commission (ECC), which affirmed the SSS's denial. Petitioner then appealed to the Court of Appeals, which dismissed her appeal, ruling that her illness was not compensable due to a failure to adduce substantial evidence proving the conditions of compensability. The Petition: Petitioner filed a petition for review on certiorari with the Supreme Court, insisting that the nature of her employment and working conditions exacerbated the risks of contracting her illness, and that the ECC committed a reversible error in finding otherwise.
Issue(s)
Whether petitioner's illness is compensable as a work-related occupational disease. Whether the quantum of evidence provided was sufficient to establish compensability under Presidential Decree (P.D.) No. 626.
Ruling
The Court reversed the decision of the Court of Appeals, holding that petitioner's illness is compensable. The Court ordered the Social Security System to pay petitioner full disability benefits as provided for under P.D. No. 626, as amended.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that cardiovascular diseases, including atherosclerotic heart disease, are specifically listed as compensable occupational diseases under ECC Resolution No. 432. The Court clarified that since the disease is listed, no further proof of causal relation between the disease and the claimant's work is strictly necessary provided the conditions of the listing are met. One such condition is when an asymptomatic person shows signs and symptoms of cardiac injury during work performance which then persist. The Petitioner showed by uncontroverted evidence that she suffered severe chest pains in the course of her employment due to work-related stress. Consequently, her heart condition fell squarely within the classification of compensable cardiovascular diseases under the Rules of the ECC. On Issue 2: The Court emphasized that the degree of proof required under P.D. No. 626 is merely substantial evidence, not certainty. Substantial evidence is defined as 'such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.' Applying the ruling in Sarmiento v. ECC, the Court noted that a claimant only needs to show that the development of the disease was brought largely by the conditions present in the nature of the job. The law requires a 'reasonable work-connection' and not a 'direct causal relation.' In this case, the probability of work-connection was established by the Petitioner’s 14-year exposure to stress and the manifestation of symptoms while on duty. Medical opinions to the contrary can be disregarded when there is a factual basis for inferring a work-connection, as 'probability, not certainty, is the touchstone.'
Main Doctrine
Cardiovascular diseases, including atherosclerotic heart disease, atrial fibrillation, and cardiac arrhythmia, are listed as compensable occupational diseases under the Employees' Compensation Commission rules. Therefore, no further proof of causal relation between the disease and the claimant's work is necessary if the disease is listed. The degree of proof required is substantial evidence, meaning such relevant evidence as a reasonable mind might accept as adequate to support a conclusion, and a reasonable work-connection is sufficient, not a direct causal relation.