Case Digest: Employees’ Compensation Commission v. Sanico, G.R. No. 134028, December 17, 1999

   Labor Law | Policy and Definitions

  • Edmund Sanico, a former employee of John Gotamco and Sons, was diagnosed with pulmonary tuberculosis (PTB) during his employment.
  • Sanico was separated from employment on December 31, 1991, due to his illness.
  • He filed a claim for compensation benefits under Presidential Decree No. 626, as amended, with the Social Security System (SSS) on November 9, 1994.
  • SSS: Denied Sanico's claim, stating it was filed beyond the three-year prescriptive period from the time the PTB first became manifest on September 21, 1991.
WoN Sanico's claim for compensation benefits had prescribed when he filed it on November 9, 1994. YES

This Court has consistently ruled that "disability should not be understood more on its medical significance but on the loss of earning capacity. Permanent total disability means disablement of an employee to earn wages in the same kind of work, or work of similar nature that [he] was trained for or accustomed to perform, or any kind of work which a person of [his] mentality and attainment could do. It does not mean absolute helplessness."  This Court has also held that:

In disability compensation, it is not the injury which is compensated, but rather it is the incapacity to work resulting in the impairment of one's earning capacity. 

Petitioner thus seriously erred when it affirmed the decision of the SSS denying private respondent's claim on the ground of prescription. In determining whether or not private respondent's claim was filed within the three-year prescriptive period under Article 201 of the Labor Code, petitioner and the SSS reckoned the accrual of private respondent's cause of action on 31 September 1991, when his PTB became known. This is erroneous.

Following the foregoing rulings, 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. Indeed, a person's disability might not emerge at one precise moment in time but rather over a period of time. 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.

In this light, the Court finds no need at this time to rule on the seeming conflict between the prescriptive period for filing claims for compensation benefits under Article 201 of the Labor Code and Article 1144(2) of the Civil Code.

In conclusion, the Court takes this opportunity to once again remind petitioner 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. Thus:

As an official agent charged by law to implement social justice guaranteed and secured by the Constitution, the ECC should adopt a liberal attitude in favor of the employee in deciding claims for compensability especially where there is some basis in the facts for inferring a work connection with the incident. 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. 4

WHEREFORE, premises considered, the instant petition is hereby DISMISSED.

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