Government Service Insurance System v. Corrales
NEW DOCTRINEFacts
The Antecedents: Respondent Astrid V. Corrales, employed with the Commission on Audit (COA), was diagnosed with Congenital Heart Disease (CHD) with severe Pulmonary Hypertension Functional Class III. She underwent surgery and filed a claim for disability benefits with the Government Service Insurance System (GSIS) for hospitalization costs. Procedural History: The GSIS denied the claim, stating that CHD is not an occupational disease under P.D. No. 626 and is a pre-existing ailment. The Employees’ Compensation Commission (ECC) affirmed the GSIS denial, citing medical studies that CHD is genetic and not work-connected. Respondent appealed to the Court of Appeals (CA), arguing that CHD is a cardiovascular disease listed as an occupational disease under Annex "A" of the Amended Rules. The CA granted, setting aside the ECC and GSIS decisions and ordering the GSIS to pay disability benefits. The CA denied the GSIS's motion for reconsideration. The Petition: The GSIS filed a Petition for Review on Certiorari with the Supreme Court, questioning the CA's reversal of the ECC's decision and arguing that CHD is not a compensable ailment under P.D. No. 626.
Issue(s)
Whether Congenital Heart Disease (CHD) is included in the category of 'Cardiovascular diseases' listed as an occupational disease under Annex 'A' of the Amended Rules on Employees' Compensation. Whether respondent's CHD is compensable under the specific conditions set forth for work-related diseases, despite its genetic and pre-existing nature.
Ruling
The petition is DENIED for lack of merit. The Court affirmed the decision of the Court of Appeals ordering the GSIS to pay respondent Astrid V. Corrales her full disability benefits.
Ratio Decidendi
On Issue 1: The Court held that Congenital Heart Disease (CHD) falls under the category of 'Cardiovascular diseases' listed in Annex 'A.' Using rules of statutory construction, the Court observed that Annex 'A' employs the term 'cardiovascular diseases' in its generic form and plural sense. When a term is pluralized in law, it must be interpreted to encompass all related meanings and types of the condition without qualification as to origin or nature. Medical literature, including Braunwald's Heart Disease, confirms that CHD is a specific form of heart disease. Consequently, CHD is a listed occupational disease, and claimants need not provide further proof of causal relation if the conditions for the disease are met. On Issue 2: The Court ruled that respondent's CHD is compensable because she met the third condition of Item 18 in Annex 'A,' which covers persons who were apparently asymptomatic before being subjected to strain at work. While respondent had a 'suspected' heart ailment in 1972, she remained asymptomatic for nearly 30 years, during which she worked and raised a family. The Clinical Abstract from the Philippine Heart Center (PHC) confirms she was asymptomatic until approximately two years Prior To Admission (PTA) in 2002. This timeline coincides with her 1998 promotion to Clerk III in the Procurement Division, which moved her from clerical work to strenuous field work involving physical inventory and canvassing under various weather conditions. The Court emphasized that even if a disease has a genetic origin, it is compensable if substantial evidence shows that work-related stress 'aroused' or 'set off' the condition. The yardstick in compensation cases is mere probability, not certainty, and any doubt must be resolved in favor of the employee.
Main Doctrine
Congenital Heart Disease (CHD), being a form of cardiovascular disease listed under Annex "A" of the Amended Rules on Employees' Compensation implementing P.D. No. 626, is compensable if it is shown that the claimant, though previously asymptomatic, experienced signs and symptoms of cardiac injury during the performance of work involving strain, and these signs and symptoms persisted, establishing a causal relationship.