GOVERNMENT SERVICE INSURANCE SYSTEM v. ANGELITA L. GABRIEL

FACTS:

The case involves an appeal regarding the denial of a claim for death benefits by Angelita L. Gabriel, as the surviving spouse of Prosecutor Rosendo Gabriel, Jr. The deceased was employed as a Prosecutor II in the Office of the City Prosecutor in Quezon City. He had more than thirty years of government service and performed duties such as conducting preliminary investigations, attending court trials, and attending inquest duties. In December 1993, he was diagnosed with "mild restrictive and obstructive pulmonary defect" and "lower esophageal obstruction probably malignant" but refused to undergo surgery. In December 1994, he was rushed to the hospital for chest pains and diagnosed with "acute myocardial infarction" and "esophageal cancer, hypertensive atherosclerotic heart disease." He subsequently suffered from diffuse myocardial ischemia and was diagnosed with "esophageal cancer, metastatic" in January 1995. He died from "cardiac arrest" secondary to esophageal cancer on January 11, 1995. The claim for death benefits was denied by the Government Service Insurance System (GSIS) and the Employees Compensation Commission due to esophageal cancer not being listed as an occupational disease. The case was elevated to the Court of Appeals, which reversed the decision of the Employees Compensation Commission. The Court ruled that even though esophageal cancer may not be compensable, the deceased also suffered from compensable ailments like acute myocardial infarction and hypertensive atherosclerotic heart disease. The immediate cause of death was "cardiac arrest," likely caused by myocardial infarction rather than esophageal cancer. The Court held that the deceased's heirs were entitled to death benefits and ordered the GSIS to pay Angelita L. Gabriel's claim.

ISSUES:

  1. Whether the resulting death of prosecutor Rosendo Gabriel, Jr. from his last illness is compensable under Presidential Decree No. 626, as amended.

RULING:

  1. The Employees Compensation Commission and the Government Service Insurance System (GSIS) erred in denying compensation benefits to the surviving spouse of the deceased. Even if esophageal cancer is not compensable, there can be no question that coronary artery disease or atherosclerotic heart disease is compensable. The deceased's immediate cause of death was "cardiac arrest", which was more likely precipitated by myocardial infarction or hypertensive heart disease rather than by esophageal cancer. Therefore, the heirs of prosecutor Rosendo Gabriel, Jr. are entitled to death benefits.

PRINCIPLES:

  • The incidence of a listed occupational disease, whether or not associated with a non-listed ailment, is enough basis for requiring compensation.

  • Hypertension, heart ailment, and ischemic heart disease are compensable under the Employees Compensation Act.

  • Benefits under the Employees Compensation Act for total permanent disability or death are the same.