Barsolo v.

SSS
G.R. 187950 | January 11, 2017
Subject Labor Law

Facts:
Barsolo's deceased husband Manuel "was employed as a seaman by various companies from 1988 to
2002." Vela was his last employer before he died in 2006. After his separation from employment with
Vela, he was diagnosed numerous diseases. When he died the autopsy report listed myocardial infarction
as his cause of death. Believing that the cause of Manuel's death was work-related, Cristina filed a claim
for death benefits under Presidential Decree No. 626, as amended, with the Social Security System, who
denied her claim on the ground that there was no longer an employer-employee relationship at the time
of Manuel's death and that "[h]is being a smoker increased his risk of contracting the illness." Cristina
appealed her case to the Employees' Compensation Commission (Commission), who didn’t rule in her
favor as well. CA also denied. Hence, this Petition was filed. Petitioner avers that even if her husband had
a history of smoking, it cannot be denied that the cause of his death is a compensable disease and that
his work as a seaman aggravated his ailment.

Issues:
(1) WON Cristina is entitled to compensation for the death of her husband. NO
 COURT ALREADY RULED THAT MYOCARDIAL INFARCTION IS ONLY COMPENSABLE WHEN
SUBSTNATIAL EVIDENCE IS ADDUCED TO PROVE THE FOLLOWING CONDITIONS:
o a) If the heart disease was known to have been present during employment there must
be proof that an acute exacerbation clearly precipitated by the unusual strain by reason
of the nature of his work;
o 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 assault to constitute
causal relationship.
o c) If a person who was apparently asymptomatic before subjecting himself to strain of
work showed signs and symptoms of cardiac injury during the performance of his work
and such symptoms and signs persisted, it is reasonable to claim a causal relationship.
 IN THIS CASE:
o MedCert did not help P’s cause because it only showed that the husband was already
suffering from hypertension even before his pre-employment examination, and that he
did not contract it during his employment with Vela.
o She also failed to adduce any proof that her husband experienced any symptom of heart
ailment while employed with Vela, nor any sign that his heart condition was aggravated
by his job.
o Husband also died 4 years after he disembarked from the ship, so other factors have
already played a role in aggravating his illness.
o Further, he was a smoker. The presence of a dfferent major causative factor, which could
explain the illness and eventual death defeats P’s claim.
 Withdrawal is made by a duly accredited and registered agricultural cooperative
in good standing (as evidenced by a cert. of good standing issued by the CDA)
 Cooperative is a producer of the sugar being withdrawn
 They subsequently sold the same to either its members of another agricultural
cooperative
 Findings of facts of quasi-judicial agencies are accorded great respect and, at times, even finality
if supported by substantial evidence. We find no reason to overturn their findings.