CASE ANALYSIS

PART I
G.R. No. 170743
Date: April 12, 2007

PART II
Petitioner: GOVERNMENT SERVICEINSURANCE SYSTEM
Respodent: LUCITA R. VILLAREAL
Nature of the case: Civil case

PART III
Facts of the case: Respondent is the widow of Zacarias F. Villareal, a technical education and skills development supervisor in the Technical Education and Skills Development Authority at the time of his death on October 20, 2002 due to myocardial infarction. Respondent filed with petitioner a claim for death benefits under PD 626, as amended. Petitioner denied the claim on the ground that the cause of death was not work-connected. The ECC upheld petitioner. On appeal, however, the CA reversed petitioner and the ECC and held that myocardial infarction, a cardiovascular disease, was a compensable occupational disease. Thus, this petition. Is respondent entitled to compensation for her husband’s death? Yes, she is. Under PD 626, the beneficiaries of an employee are entitled to death benefits under the system if the cause of death of the employee is a sickness listed as an occupational disease by the ECC or any other illness caused by employment, subject to proof that the risk of contracting the same is increased by the working conditions. The CA correctly ruled that myocardial infarction was considered as an occupational disease because it was included under the classification “cardiovascular disease,” a compensable occupational disease under ECC Resolution No. 432 (dated July 20, 1977) subject to substantial evidence proving any of the following conditions:

(a) If the heart disease was known to have been present during employment, there must be proof of an acute exacerbation clearly precipitated by the unusual strain by reason of the nature of this work. (b) The strain of work that brings about an acute attack