EMPLOYEES' COMPENSATION COMMISSION (SOCIAL SECURITY SYSTEM) vs.

EDMUND SANICO
G.R. No. 134028
December 17, 1999

Facts:
Private respondent was a former employee of John Gotamco and Sons. He worked in said company
as "wood filer" from 1986 until he was separated from employment due to his illness (pulmonary
tuberculosis (PTB)).
On November 1994, private respondent filed with the SSS a claim for compensation benefits under
P.D. No. 626, as amended. It was denied on the ground of prescription. The SSS ruled that under
Article 201 or the Labor Code, a claim for compensation shall be given due course only when the
same is filed with the System three (3) years from the time the cause of action accrued. In private
respondent's case, the SSS reckoned the three-year prescriptive period on September 21, 1991
when his PTB first became manifest. Thus, the claim had allegedly already prescribed.
On appeal, petitioner affirmed the decision of the SSS.
The CA reversed petitioner's decision.

• The CA reconciled Article 201 of the Labor Code with Article 1144(2) of the Civil Code.
Under the latter provision of law, an action upon an obligation created by law must be filed
within ten (10) years from the time the cause of action accrues. Thus, while private
respondent's illness became manifest in September 1991, the filing of his compensation
claim on November 1994 was within the prescriptive period.

Issue:
Whether or not private respondent's claim for compensation benefit had already prescribed when
he filed his claim on November 1994

Ruling:
No, it has not yet prescribed.
The prescriptive period for filing compensation claims should be reckoned from the time the
employee lost his earning capacity, i.e., terminated from employment, due to his illness and not
when the same first became manifest.
In this case, private respondent's employment was terminated on 31 December 1991 due to his
illness, he filed his claim for compensation benefits on 9 November 1994. Accordingly, private
respondent's claim was filed within the three-year prescriptive period under Article 201 of the
Labor Code.
The Court also noted that P.D. No. 626, as amended, is a social legislation whose primordial
purpose is to provide meaningful protection to the working class against the hazards of disability,
illness and other contingencies resulting in the loss of income.
The ECC should adopt a liberal attitude in favor of the employee in deciding claims for
compensability. This kind of interpretation gives meaning and substance to the compassionate
spirit of the law as embodied in Article 4 of the New Labor Code which states that all doubts in
the implementation and interpretation of the provisions of the Labor Code including its
implementing rules and regulations should be resolved in favor of labor.