GSIS V. CUNTAPAY (ADMINISTRATIVE)

For sickness to be compensable, the claimant must prove either

1. that the sickness is the result of an occupational disease listed under the Rules on Employees' Compensation and the conditions set therein are satisfied; or
2. that the risk of contracting the disease was increased by the claimant's working condition.

ECC Resolution 432 dated 20 July 1977 includes cardio-vascular or heart diseases in the list of occupational diseases and enumerated the conditions under which they are considered work-related and thus compensable.

We agree with GSIS considering that there was indeed no proof that any of said conditions has been satisfied. There was no evidence to show that respondent was previously diagnosed with a heart ailment or that he was under a severe strain of work sufficient to have caused the heart attack since a board meeting could hardly inflict such a severe strain.

To successfully recover compensation for his heart ailment, the respondent must therefore prove through substantial evidence that the risk of contracting the disease was increased by the nature of his work and working conditions.