Conditions under which cardio-vascular or heart diseases can be considered as work-related and thus compensable

The second issue of whether or not the illness of petitioner’s husband, myocardial infarction which was the cause of his death is work-related, must likewise be resolved in favor of the petitioner.

Under the law on employees’ compensation, death is compensable only when it results from a work-connected injury or sickness.  In the instant case, the cause of petitioner’s husband’s death was myocardial infarction and it must be considered work-connected.  While it is true that myocardial infarction is not among the occupational diseases listed under Annex “A” of the Amended Rules on Employees’ Compensation, the Commission, under ECC Resolution No. 432 dated July 20, 1977, laid down the conditions under which cardio-vascular or heart diseases can be considered as work-related and thus compensable, viz:

(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/her/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 insult 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/her work and such symptoms and signs persisted, it is reasonable to claim a causal relationship.

Myocardial infarction is also known as heart attack.  It results in permanent heart damage or death.  A heart attack is called myocardial infarction because part of the heart muscle (myocardium) may literally die (infarction).  This occurs when a blood clot blocks one of the coronary arteries (the blood vessels that bring blood and oxygen to the heart muscle).  When the heart muscle does not obtain the oxygen-rich blood that it needs, it will begin to die.  The severity of a heart attack usually depends on how much of the heart muscle is injured or dies during the heart attack.  Heart attack accounts for 1 out of every 5 deaths.  It is a major cause of sudden death in adults.  Heavy exertion or emotional stress can trigger a heart attack.[16]

In the case at bar, the petitioner’s husband’s heart disease falls under the second condition of ECC Resolution No. 432 dated July 20, 1977 which states that the strain of work that brought about the 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.  Petitioner’s husband was driving a dump truck within the company premises where they were stacking gravel and sand when he suffered the heart attack.  He had to be taken down from the truck and brought to the workers’ quarters where he expired at 10:30 a.m., just a few minutes after the heart attack, which is much less than the 24 hours required by ECC Resolution No. 432.  This is a clear indication that severe strain of work brought about the acute attack that caused his death.

Professional drivers, especially truck drivers like the decedent in the instant case, carry the burden of being more exposed and subjected to the stress and strain of everyday traffic, and the greater physical exertion brought about by driving a large and heavy vehicle.  In addition, according to the petitioner, her husband was under a lot of stress in the workplace.  He was a model worker and his employer highly depended on him.  He became the object of envy of his co-workers which caused him much emotional stress.  Add to this the fact that he has been a truck driver for more than twenty-four (24) years.  Due to the combination of emotional stress and vigorous physical exertion, it was easy for him to succumb to the heart ailment.  We hold that the illness of the decedent which caused his death is work-connected, and thus compensable by virtue of ECC Resolution No. 432 dated 20 July 1977.

As a final note, we find it necessary to reiterate that P.D. No. 626, as amended, is a social legislation whose primordial purpose is to provide meaningful protection to the working class against the hazards of disability, illness and other contingencies resulting in the loss of income.  Thus, as the official agents charged by law to implement social justice guaranteed by the Constitution, the ECC and the SSS should adopt a liberal attitude in favor of the employee in deciding claims for compensability especially where there is some basis in the facts for inferring a work connection with the illness or injury, as the case may be.  It is only this kind of interpretation that can give meaning and substance to the compassionate spirit of the law as embodied in Article 4 of the New Labor Code which states that all doubts in the implementation and interpretation of the provisions of the Labor Code including its implementing rules and regulations should be resolved in favor of labor.[17]


About Erineus

Born on December 28, 1965, Surallah, South Cotabato, Southern Mindanao, Philippines.
This entry was posted in ECC, Social Legislations, SSS, State Policies and tagged . Bookmark the permalink.

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