CASE DIGEST: GSIS v. Esteves

 


GOVERNMENT SERVICE INSURANCE SYSTEM, petitioner, vs. FE L. ESTEVES, respondent
G.R. No. 182297                |              June 21, 2017

 

TOPIC: Health, safety and social welfare benefits

FACTS:

Antonio Esteves, Sr. was employed as a utility worker at the Gubat District Hospital from December 1978 until the time of his death on August 5, 2000. His s duties consisted of the following: 1) prepares beds and distributes bedpans; 2) mops, scrubs, polishes furniture, and removes dust in the wards; 3) carries patients, distributes clean clothes and linens, and collects soiled ones; 4) renders personal services to patients and runs errands for nurses and doctors.

On August 5, 2000, Antonio Esteves, Sr. was rushed to the hospital due to body weakness, headache and vomiting and later died.

Believing that the death of her husband was work-related and compensable, respondent filed a claim for death benefits with the GSIS. However, petitioner denied respondent’s claim on the ground that Antonio’s underlying cause of death, Non-Insulin Dependent Diabetes Mellitus, is not considered as work-related.

ISSUE:

Whether or not Esteves’ disease can be considered work-related

RULING:

Respondent failed to present sufficient evidence to establish that the death of the deceased was compensable. It is not sufficient that the fact of cerebrovascular accident (CVA) or hypertension is proven; in order to become compensable, certain conditions must be complied with. The Court explained in Government Service Insurance System v. Calumpiano, that although cerebrovascular accident and essential hypertension are listed occupational diseases, their compensability requires compliance with all the conditions set forth in the Rules. In short, both are qualified occupational diseases. For cerebrovascular accident, the claimant must prove the following: (1) there must be a history, which should be proved, of trauma at work (to the head specifically) due to unusual and extraordinary physical or mental strain or event, or undue exposure to noxious gases in industry; (2) there must be a direct connection between the trauma or exertion in the course of the employment and the cerebrovascular attack; and (3) the trauma or exertion then and there caused a brain hemorrhage. On the other hand, essential hypertension is compensable only if it causes impairment of function of body organs like kidneys, heart, eyes and brain, resulting in permanent disability, provided that, the following documents substantiate it: (a) chest X-ray report; (b) ECG report; (c) blood chemistry report; (d) funduscopy report; and (e) CT scan.


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