Scribd
Upload
108 views2 pages

GSIS VS. ESTEVES, G.R. NO. 182297, JUNE 21, 2017 (Employees' Compensation)

This case involves a claim for death benefits filed by the respondent with the GSIS after her husband, who worked as a utility worker at a hospital, died after being rushed to the same hospital due to body weakness, headache, and vomiting. The GSIS denied the claim finding the underlying cause of death, Non-Insulin Dependent Diabetes Mellitus, was not work-related. The CA reversed finding the death compensable under PD 626. However, the Supreme Court ruled the death was not compensable as the respondent failed to present sufficient evidence that the risk of contracting diabetes was increased by the working conditions or that any conditions for occupational disease coverage under the Amended Rules were met.

Uploaded by

mae ann rodolfo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
108 views2 pages

GSIS VS. ESTEVES, G.R. NO. 182297, JUNE 21, 2017 (Employees' Compensation)

This case involves a claim for death benefits filed by the respondent with the GSIS after her husband, who worked as a utility worker at a hospital, died after being rushed to the same hospital due to body weakness, headache, and vomiting. The GSIS denied the claim finding the underlying cause of death, Non-Insulin Dependent Diabetes Mellitus, was not work-related. The CA reversed finding the death compensable under PD 626. However, the Supreme Court ruled the death was not compensable as the respondent failed to present sufficient evidence that the risk of contracting diabetes was increased by the working conditions or that any conditions for occupational disease coverage under the Amended Rules were met.

Uploaded by

mae ann rodolfo
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

GSIS VS. ESTEVES, G.R. NO.

182297, JUNE 21, 2017

https://www.chanrobles.com/cralaw/2017junedecisions.php?id=357

FACTS:

On August 5, 2000, Antonio Estevez, Sr., employed as a utility worker at the Gubat
District Hospital (GDH), was rushed to the hospital due to body weakness, headache
and vomiting. A few hours after he was rushed to the hospital, Antonio Esteves, Sr.
died.

Believing that the death of her husband was work-related and compensable under P.D.
No. 626, [respondent] filed a claim for death benefits with the Government Service
Insurance System (GSIS).  GSIS, however, 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.

Aggrieved, respondent appealed to the ECC,which dismissed the claim for lack of merit.

On appeal, the CA reversed and set aside the decision of ECC and directed the GSIS to
promptly pay petitioner Fe L. Esteves compensation arising from the death of her
husband, Antonio Esteves, Sr., pursuant to P.D. No. 626, as amended.

ISSUE

Whether the underlying cause of death of the late Antonio Esteves, Sr., which was
Diabetes Mellitus as indicated in his death certificate, and his other ailments as merely
complications of his Diabetes, may be considered compensable under P.D. No. 626, as
amended.

RULING

No. Under Section 1, Rule III of the Amended Rules on Employees' Compensation, the
above provision was clarified as follows:

SECTION 1. Grounds. (a) For the injury and the resulting disability or death to be
compensable, the injury must be the result of accident arising out of and in the course
of the employment. (ECC Resolution No. 2799, July 25, 1984).

(b) 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.
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 CA does not point out the specific observations or statements in the specific
certification that would establish the conditions set forth in the Amended Rules.

Nevertheless, in the very first condition provided in Annex "A" of the Amended Rules,
evidence must be presented to show a history of any trauma to the head at work.
There was never any evidence of this. There was never any mention of any head
trauma that the deceased suffered. There being no evidence of trauma, the connection
to the brain hemorrhage cannot be established.

As to his hypertension, the ECC found that he did not have any history and that it
caused impairment of the function of body organs like kidneys, heart, eyes and brain.
None of the medical reports had established the same.

Evidently, the death of Emilio cannot be concluded as compensable.

You might also like