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SC tells state social service agencies to adopt liberal attitude in deciding claims

/ 04:39 PM February 28, 2013


MANILA, Philippines – Be considerate in dealing with employees’ claims, the Supreme Court reminded the Government Service Insurance System (GSIS), Social Security Network (SSS), Employees Compensation Commission (ECC).

In an 8-page decision by the high court’s second division released Thursday, it affirmed the Court of Appeals’ decision to grant the death benefits to the survivors of Bernardo Alcaraz, a laborer and Metro Aide I at the Metro Manila Development Authority (MMDA).

“We take this occasion to reiterate that as an agency charged by law with implementation of social justice guaranteed and secured by the Constitution—the ECC (as well as the GSIS and SSS)—should adopt a liberal attitude in favor of the employees in deciding claims for compensability, especially where there is some basis in the facts for inferring a work-connection to the accident or illness. This is what the Constitution dictates,” the high court, through Associate Justice Arturo Brion said.


Alcaraz has been working with the MMDA for almost 29 years. In 2004, he was diagnosed with pulmonary tuberculosis and community acquired pneumonia. He was also confined at the Ospital ng Makati.

On January 15, 2005, he was found dead at the basement of the MMDA building. Autopsy showed that he died of myocardial infraction (heart attack).

His widow, Marilou filed a claim for death benefits with the GSIS which denied the claim saying the cause of death was not work related but is related to diabetes. She then took her case to the ECC who affirmed the GSIS’ findings prompting her to appeal before the Court of Appeals.

The appeals court reversed GSIS and ECC saying there is enough proof of work connection to the death of Alcaraz. It believed that his work as laborer and metro aide have substantially contributed to his illness. GSIS then took the case to the Supreme Court alleging that the appeals court committed grave abuse of discretion.

But the high court, through Associate Justice Arturo Brion, said the Court of Appeals was correct in saying that the hazardous working environment of Alcaraz aggravated his illness.

“The conclusions of the two agencies totally disregarded the stressful and strenuous conditions under which Bernardo toiled for almost 29 long years as a laborer and as a metro aide,” the high court said taking note of the fact that Bernardo died at his employer’s premises.

The high court added that considering that Alcaraz died a few months after he was hospitalized “a reasonable mind analysing these facts cannot but arrive at the conclusion that the risks present in his work environment for the entire duration of his employment precipitated the acute myocardial infarction that led to his death.”

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