SALLY A. RODRIGUEZ, PETITIONER, VS. EMPLOYEES’ COMPENSATION COMMISSION (ECC), SOCIAL SECURITY SYSTEM (SSS), GLOBE COCO PRODUCTS MANUFACTURING CORP., RESPONDENTS.

Rodriguez versus Employees' Compensation Commission

The Case

Sally Rodriguez, the widow of Emiliano Rodriguez Junior, filed a claim for death and funeral benefits under the Employees' Compensation Law after her husband, an expeller mechanic, died of a heart attack while at work. The Social Security System denied the claim, and the Employees' Compensation Commission affirmed the denial, so Sally brought the matter to the Supreme Court on a petition for review. The case matters because it is the Court's clearest statement that a listed occupational disease such as cardiovascular disease is compensable on a showing of reasonable work connection, and that an employee's smoking habit cannot by itself defeat a claim.

Procedural History

Sally filed her claim for death and funeral benefits with the Social Security System in Legazpi City. The branch denied the claim, and the Medical Operations Department likewise denied it on the ground that the illness was not shown to be work connected. Sally appealed to the Employees' Compensation Commission, which affirmed the denial in its decision dated 29 October 2012. From that decision she filed a petition for review with the Supreme Court under Rule 43 of the Rules of Court, and the Court granted the petition.

Facts

Emiliano Rodriguez Junior worked for Globe Coco Products Manufacturing Corporation as an Expeller Mechanic for Maintenance from 7 January 2008 until 6 January 2011. Before he was hired, he underwent a pre-employment medical examination on 5 July 2007, and his medical certificate declared him physically fit and healthy. His duties included maintaining the machines during breakdowns and shutdowns, assisting the leadman, coordinating with the expeller operator whenever the machine had trouble, cleaning the machines to prevent lubricant leaks, and working under the leadman's supervision.

At around 9:15 in the morning of 6 January 2011, while replacing some parts of the copra mill flakers, Emiliano suddenly felt chest pain. He stopped working and rested in the boiler room. A few minutes later he complained of severe chest pain and asked to be rushed to the nearest hospital. At around 11:30 that same morning, he was pronounced dead at Tanchuling Hospital in Legazpi City. The immediate cause of death was cardio-respiratory arrest, the antecedent cause was acute myocardial infarction, and the underlying cause was gastroenteritis with dehydration, moderate.

On 13 April 2011, Sally filed her claim for death and funeral benefits. The Social Security System denied it, reasoning that his being a smoker and occasional drinker increased his risk of cardiovascular disease and that his work as a mechanic had no causal relationship to the myocardial infarction. The Employees' Compensation Commission affirmed, stressing that there was no substantial evidence of unusual strain at work and that his history of cigarette smoking precipitated his heart ailment.

Issues

• Whether or not the myocardial infarction, or heart attack, that caused Emiliano's death is compensable.
• Whether or not that myocardial infarction is work connected.
• Whether or not there was proof that the risk of contracting the illness was increased by the factors attendant to his employment.

Applicable Provisions

Section 1, paragraph b, of Rule III of the Amended Rules Implementing the Employees' Compensation Law provides:

For the sickness and the resulting disability or death to be compensable, the sickness must be the result of an occupational disease listed under Annex A of these Rules with the conditions set therein satisfied, otherwise, proof must be shown that the risk of contracting the disease is increased by the working conditions.

This fixes the two alternative routes to compensability, and the Court found that Emiliano's illness satisfied both.

Item 18 of Annex A of the Amended Rules on Employees' Compensation provides:

Cardio-vascular diseases. Under any of the following conditions: (a) If the heart disease was known to have been present during employment, there must be proof that an acute exacerbation was clearly precipitated by the unusual strain by reasons of the nature of his or her work. (b) 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 injury to constitute causal relationship. (c) If a person who was apparently asymptomatic before being subjected to strain at work showed signs and symptoms of cardiac injury during the performance of his or her work and such symptoms and signs persisted, it is reasonable to claim a causal relationship.

The Court placed Emiliano's case squarely under the second condition, because the fatal attack came within two hours of the strain of work.

Ruling

On the first issue, the Court held that the myocardial infarction is compensable. Myocardial infarction, or heart attack, falls within the classification of cardiovascular disease, which the Commission itself included in the list of occupational and compensable diseases through its resolution approved on 20 July 1997.

On the second issue, the Court held that the illness is work connected. Emiliano was certified physically fit and healthy before his employment. As an expeller mechanic he had to make long routine inspections of the company's heavy machinery and equipment daily throughout his eight hour shift. At around 9:15 in the morning of 6 January 2011 he was replacing parts of the copra mill flakers when the chest pain struck, and he died at around 11:30, only two hours later, well within the twenty four hours required by Item 18. That sequence showed that a severe strain of work brought about the acute attack that killed him.

On the third issue, the Court held that the risk of contracting the illness was increased by his working conditions, so the second criterion for compensability was also present. The Court rejected the Social Security System's narrow reliance on his eight year smoking habit, quoting its earlier ruling in the Government Service Insurance System versus De Castro case that smoking and drinking are not the sole causes of cardiovascular disease and should not be taken alone as barring a claim. The Court stressed that what the law requires is a reasonable work connection and not a direct causal relation, and that probability, not certainty, is the touchstone. It is enough that the employment contributed, even if only to a small degree, to the development of the disease.

Finally, the Court reminded the Commission and the Social Security System that the Employees' Compensation Law is social legislation, and that as official agents of social justice they should adopt a liberal attitude in favor of the employee, resolving doubts in favor of labor.

Doctrine

A Bar candidate should retain these rules. First, cardiovascular disease, including myocardial infarction, is a listed occupational disease under Item 18 of Annex A of the Amended Rules on Employees' Compensation, and is compensable under any of the three conditions stated there. Second, under the second condition, the strain of work that brings about the acute attack must be of sufficient severity and must be followed within twenty four hours by the clinical signs of a cardiac injury to constitute causal relationship. Third, compensability may rest either on the illness being a listed occupational disease or on proof that the risk of contracting it is increased by the working conditions. Fourth, the degree of proof is merely substantial evidence, and what the law requires is a reasonable work connection, not a direct causal relation; probability, not certainty, is the touchstone. Fifth, smoking and drinking are not the sole causes of cardiovascular disease and cannot by themselves bar compensability. Sixth, the Employees' Compensation Law is social legislation, and all doubts should be resolved in favor of labor.

Disposition

The Supreme Court granted Sally Rodriguez's petition, reversed and set aside the decision of the Employees' Compensation Commission, and directed the Social Security System to pay her the proper death benefits for her husband.

Remember This

Memorize the line that probability, not certainty, is the touchstone, and that a reasonable work connection suffices for compensability. Examiners use this case to test the twenty four hour rule under Item 18 and the rule that smoking and drinking do not automatically defeat a claim for death benefits.