Rañises v. Employees Compensation Commission
REITERATIONFacts
1. The Antecedents: Petitioner Manuel Rañises was employed as a driver-messenger from November 11, 1994, to April 9, 1998. On August 29, 1997, while on assignment, he experienced chest pains and was subsequently diagnosed with Coronary Artery Disease/Antero Septal Wall, Myocardial Infarction. He filed a claim for compensation benefits under P.D. No. 626, as amended, asserting his ailment was work-related. The Social Security System (SSS) denied the claim, stating there was no causal relationship between his ailment and his work. The Employees' Compensation Commission (ECC) affirmed the SSS decision, dismissing the case for lack of merit. 2. Procedural History: Following the denial of his claim by the SSS and the affirmation by the ECC, petitioner Manuel Rañises filed a petition for review with the Court of Appeals. The Court of Appeals, in its Decision dated September 24, 1999, affirmed the ECC's decision and dismissed Rañises' petition. A subsequent motion for reconsideration filed by Rañises was denied by the Court of Appeals in its Resolution dated December 28, 1999. 3. The Petition: Petitioner Manuel Rañises filed the instant petition for review on certiorari with the Supreme Court, assailing the Decision and Resolution of the Court of Appeals. He seeks to have his claim for compensation benefits under P.D. No. 626, as amended, declared compensable. The sole issue presented to the Supreme Court is whether petitioner's claim under P.D. 626 is compensable, arguing that his myocardial infarction was a result of the strain and stress inherent in his work as a driver-messenger.
Issue(s)
Whether petitioner's claim for compensation benefits under P.D. No. 626 is compensable. Whether myocardial infarction suffered by the petitioner is a work-related illness.
Ruling
The petition is GRANTED. The assailed Decision and Resolution of the Court of Appeals are REVERSED. The Social Security System is ordered to pay Manuel Rañises, petitioner, the compensation benefits due him under P.D. No. 626, as amended.
Ratio Decidendi
On whether petitioner's claim for compensation benefits under P.D. No. 626 is compensable: The Supreme Court held that P.D. No. 626, as amended, is a social legislation aimed at providing protection to workers. The Court found that the petitioner's work as a driver-messenger subjected him to severe strain, fatigue, and stress due to driving around Metro Manila, delivering equipment, collecting checks, and transporting guests amidst traffic. The Court agreed with the Solicitor General that the petitioner's ailment was work-connected and therefore compensable. The Court noted that Section 1(h), Rule III of the ECC Amended Rules on Employees Compensation considers cardio-vascular disease, including myocardial infarction, as a compensable occupational disease under specific conditions. The Court found that the petitioner met the third condition, where an apparently asymptomatic person shows signs and symptoms of cardiac injury during the performance of work, establishing a causal relationship. The Court cited several previous rulings where myocardial infarction was considered compensable, emphasizing the policy of the State to give maximum aid and protection to labor. The Court disagreed with the Court of Appeals' finding that the petitioner's work did not entail the necessary risks, highlighting that the petitioner was certified to be in good health prior to his employment and that his daily tasks involved significant physical and mental exertion. On whether myocardial infarction suffered by the petitioner is a work-related illness: The Supreme Court ruled in the affirmative. The Court reiterated that cardio-vascular disease, including myocardial infarction, is considered a compensable occupational disease under P.D. No. 626, as amended, provided substantial evidence proves the conditions outlined in the ECC Amended Rules. The Court found that the petitioner's employment as a driver-messenger, which involved prolonged driving, exposure to traffic stress, and physical demands, directly contributed to the development of his myocardial infarction. The Court applied the presumption that when an employee enters employment in good health and suffers an illness during employment that he never had before, the illness is presumed to be compensable. The Court emphasized that any kind of work produces stress and strain, leading to wear and tear of the human body, and that acute myocardial infarction is listed as an occupational disease sufficient for compensation.
Main Doctrine
Myocardial infarction, when arising in the course of employment and supported by substantial evidence demonstrating a causal relationship between the strain of work and the ailment, is a compensable illness under P.D. No. 626, as amended.