GR 134028; (December, 1999) (Digest)
G.R. No. 134028 December 17, 1999
EMPLOYEES’ COMPENSATION COMMISSION (SOCIAL SECURITY SYSTEM), petitioner, vs. EDMUND SANICO, respondent.
FACTS
Respondent Edmund Sanico worked as a wood filer for John Gotamco and Sons from 1986 until his separation on December 31, 1991, due to his illness. A medical evaluation report dated September 31, 1991, indicated he was suffering from pulmonary tuberculosis (PTB), which was later confirmed by chest x-rays in 1994 and 1995. On November 9, 1994, Sanico filed a claim for compensation benefits under Presidential Decree No. 626, as amended.
The Social Security System (SSS) denied the claim on April 23, 1996, on the ground of prescription. The SSS, affirmed by the petitioner Employees’ Compensation Commission, reckoned the three-year prescriptive period under Article 201 of the Labor Code from September 1991, when his PTB first became manifest. Since the claim was filed in November 1994, it was deemed to have prescribed. On appeal, the Court of Appeals reversed this decision, holding the claim was filed within the prescriptive period, prompting the petitioner to elevate the case to the Supreme Court.
ISSUE
The sole issue is whether or not private respondent’s claim for compensation benefits had already prescribed when filed on November 9, 1994.
RULING
The Supreme Court ruled in favor of respondent Sanico, dismissing the petition. The Court clarified that the prescriptive period for filing a compensation claim should be reckoned from the time the employee loses his earning capacity due to the illness, not from the time the illness first becomes manifest. Disability in compensation law refers to the loss of earning capacity, not merely the medical onset of the disease. Since Sanico was terminated from employment on December 31, 1991, due to his illness, the filing of his claim on November 9, 1994, was well within the three-year prescriptive period under Article 201 of the Labor Code.
The Court emphasized that P.D. No. 626 is a social legislation designed to protect workers, and its provisions should be liberally construed in favor of labor. Given that the claim was timely filed under the correct reckoning point, the Court found no need to resolve the alleged conflict between Article 201 of the Labor Code and Article 1144(2) of the Civil Code regarding prescriptive periods. The decision of the Court of Appeals was affirmed.