Social Security System v. Cuento
REITERATIONFacts
The Antecedents: Maximo M. Cuento (Maximo), employed as a motorized messenger, was diagnosed with a transient ischemic attack on June 15, 2011. On October 4, 2011, while on duty, Maximo suffered what appeared to be a stroke and was declared "dead on arrival" at the hospital. His Post Mortem Death Certificate listed myocardial infarction as the cause of death. Procedural History: Respondent Belinda C. Cuento filed a claim for death benefits with the Social Security System (SSS), which was denied. The denial was affirmed by the Employees' Compensation Commission (ECC), which ruled that there was no showing of unusual strain at work and no substantial evidence of a causal relationship between Maximo's ailment and his working conditions. The Court of Appeals (CA) reversed the ECC's decision, finding that Maximo's duties as a messenger, involving exposure to heat, rain, and pollution, aggravated his condition and that his myocardial infarction was work-connected and compensable. The Petition: The SSS filed a Petition for Review on Certiorari, arguing that Maximo's myocardial infarction was neither caused nor aggravated by the unusual strain of his job and that the respondent failed to adduce substantial evidence to show compliance with the law's conditions for compensability.
Issue(s)
Whether Maximo's myocardial infarction is a compensable disease under PD 626, as amended, considering the conditions for compensability. Whether there is substantial evidence to establish a causal relationship between Maximo's work as a motorized messenger and his death due to myocardial infarction, considering the working conditions and the principle of liberal interpretation.
Ruling
The petition is without merit. The Court affirmed the Decision of the Court of Appeals, ordering the SSS to pay the respondent the proper benefits for the death of her husband, Maximo M. Cuento.
Ratio Decidendi
On whether Maximo's myocardial infarction is a compensable disease under PD 626, as amended: The Court held that myocardial infarction falls under cardiovascular diseases, which are compensable under ECC Board Resolution No. 11-05-13 under specific conditions. The case falls under condition (b), which states that "the strain of work that brings about an acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship." Maximo suffered loss of consciousness while on duty and died within 24 hours due to myocardial infarction. The Court found substantial evidence to rule that his death is compensable. On whether there is substantial evidence to establish a causal relationship between Maximo's work and his death: The Court found that the conditions of compensability were present. First, the working conditions of a motorized messenger, involving exposure to heat, rain, and pollution, clearly involved risks that could lead to the illness. Second, the stress and strain of navigating Metro Manila under adverse weather conditions were major factors contributing to his death. Third, prolonged exposure to these environmental stressors was deemed the main contributor to his death. The Court reiterated the ruling in Rañises v. Employees Compensation Commission that a messenger's job, involving driving around Metro Manila and exposure to traffic stress, can cause severe strain and fatigue, making the ailment work-connected and compensable. The Court concluded that a reasonable mind analyzing the facts cannot but conclude that the risks present in Maximo's working environment precipitated the myocardial infarction that led to his death. Furthermore, the Court emphasized that agencies like the ECC, GSIS, and SSS should adopt a liberal attitude in favor of employees in deciding claims for compensability, especially when there is some basis for inferring a work-connection, as mandated by social justice principles.
Main Doctrine
Myocardial infarction, a cardiovascular disease, is compensable under PD 626 as amended, if there is substantial evidence showing a causal relationship between the strain of work and the acute attack, particularly when the strain is of sufficient severity and is followed within 24 hours by clinical signs of a cardiac insult.