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Case Title: Date of Decision: GR No.

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ALEXANDER B. GATUS (petitioner) vs. SOCIAL SECURITY SYSTEM (respondent) January 26, 2011 174725 Grounds and Requisites for a Disease of Sickness to be Compensable under the SSS Law and Implementing Rules and Regulations. (1) Coronary Artery Disease a Compensable Disease under the SSS Law. (2) Quantum of Evidence to prove that the Disease/Sickness is Compensable. (3) Necessary Party to Prove the Compensability of the Disease/Sickness

FACTS: Gatus worked at the Central Azucarera de Tarlac for a period of 30 years. During his employment, he contracted disease and was diagnosed to be suffering from Coronary Artery Disease (CAD): Triple Vessel and Unstable Angina. His medical records showed him to be hypertensive for 10 years and a smoker. He was given by the SSS the following EC/SSS Permanent Partial Disability (PPD) benefits: (a) 8 monthly pensions effective September 1, 1994 and (b) 4 monthly pensions effective January 3, 1997. He became an SSS retirement pensioner on February 1, 2002. However, an SSS audit revealed the need to recover the EC benefits already paid to him on the ground that his CAD, being attributed to his chronic smoking, was not work-related. He was notified thereof through a letter dated July 31, 2003. Petitioner, believing he was entitled to such benefits, assailed the decision of the SSS. SSS denied the petition. He then elevated to the ECC ruled against the Petitioner. Further, CA ruled that the Petitioner is not entitled to the benefits under Presidential Decree No. 626. Hence, this Petition. ISSUE/S: (1) Whether or Not the Petitioner is entitled to the Benefits under Presidential Decree No. 626. DECISION: The Supreme Court held that the Petitioner is not entitled to the benefits under Presidential Decree No. 626 and upheld the ruling of the CA. In its decision, the Court mentioned of Section 1, Rule III of the Amended Rules on Employees Compensation states that the sickness must be the result of an occupational disease listed thereon otherwise proof must be shown that the risk of contracting the disease is increased by the working conditions. The Petitioner in this case failed to prove the compensability of his disease, thus, he was not able to prove with substantial evidence that indeed he is entitled to the benefits under PD 626. The burden of proof is thus on petitioner to show that any of the above conditions have been met in his case. The required proof is further discussed in Ortega v. Social Security Commission: The requisite quantum of proof in cases filed before administrative or quasi-judicial bodies is neither proof beyond reasonable doubt nor preponderance of evidence. In this type of cases, a fact may be deemed established if it is supported by substantial evidence, or that amount of relevant evidence which a reasonable mind might accept as adequate to justify a conclusion. In this case, substantial evidence abounds.