Employee Death due to Work-Related Myocardial Infarction is Compensable
Employee death while at work is an unfortunate event. The main concern of the bereaved family in such situation is the financial program available since the breadwinner is gone.
In a case involving a company “motorized” messenger, which is a utility person driving a motorcycle, who died of a heart attack, the Supreme Court (SC) affirmed the ruling that he is entitled to compensation in the case of Social Security System vs. Cuento (G.R. No. 225827. July 28, 2021).
The employee mentioned was diagnosed with a transcient ischemic attack. While on duty he appeared to have suffered from a stroke. He was brought to San Juan De Dios Hospital. The hospital declared him “dead on arrival.”
In the Post Mortem Death Certificate, the cause of death was myocardial infarction. The wife filed for death benefits with the SSS. However, the reviewing branch denied the claim. The denial was sustained by SSS-Medical Operations Department. The ECC also denied the appeal.
Thus, the wife appealed to the Court of Appeals (CA) which ruled in favor of the employee. The SSS
appealed to the SC which affirmed the decision of the CA.
The SC held that this case undoubtedly falls under Annex “A” of the Amended Rules on Employees’ Compensation” stating that cardiovascular disease is deemed compensable occupational disease where the strain of work that brings about an acute attack is of sufficient severity and is followed within 24 hours by the clinical sign of a cardiac insult to constitute causal relationship.
The employee was on duty as a motorized messenger when he suffered loss of consciousness and within 24 hours, he died due to myocardial infarction. The records show that he had been with Metro Bank as a motorized messenger for several months and his duties included delivery of documents to or from the main office to any Metro Bank branch in Metro Manila.
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He was deemed fit to work. Daily exposure to the heat of the sun, rain, and pollution are principal factors that cannot simply be ignored in declaring the compensability of his death.
First, the working conditions of a motorized messenger clearly involve risks (heat, rain, and pollution) of contracting the illness which caused the death of respondent’s husband. Second, the stress and strain of plying around Metro Manila under the sun or rain was the major factor that caused his death. Third, prolonged exposure to stress, heat, rain, and pollution is deemed the main contributor of the cause of his death.
The only plausible conclusion in the instant case is that he worked under risks of stress and strain that greatly contributed to his myocardial infarction. A reasonable mind analyzing these facts cannot but
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conclude that the risks present in his working environment for the entire duration of his employment precipitated the myocardial infarction that led to his death.
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