GR 160467; (April, 2009) (Digest)
G.R. No. 160467 ; April 7, 2009
SOLEDAD MUÑOZ MESA, Petitioner, vs. SOCIAL SECURITY SYSTEM and PHILROCK INCORPORATED, Respondents.
FACTS
Teodoro Mesa, the deceased husband of petitioner Soledad Muñoz Mesa, was an employee of respondent Philrock Incorporated from April 1966 to November 1998. He was diagnosed with diabetes mellitus, pulmonary tuberculosis, and ischemic heart disease and was confined from September 23 to 30, 1988. He continued working until he died of myocardial infarction on November 19, 1988. In October 2000, nearly 12 years later, petitioner filed a claim for employees’ compensation benefits under Presidential Decree (P.D.) No. 626. The Social Security System (SSS) denied the claim on the ground of prescription. The Employees Compensation Commission (ECC) sustained the denial, holding the claim prescribed on November 26, 1991, per Article 201 of P.D. 626, which requires claims to be filed within three years from the time the cause of action accrued. The Court of Appeals affirmed the ECC decision. Petitioner later submitted a “Death Disability and Retirement Claims Information” sheet showing she had filed a claim for death and funeral benefits with the SSS on December 12, 1988. The appellate court held this did not operate as constructive notice to the ECC for employees’ compensation purposes and was raised for the first time on appeal.
ISSUE
Whether petitioner’s claim for employees’ compensation benefits had prescribed.
RULING
No, the claim had not prescribed. The Supreme Court reversed the Court of Appeals. Citing Buena Obra v. SSS, the Court held that the filing of a claim for death and funeral benefits with the SSS on December 12, 1988, served as constructive notice to the SSS/ECC pursuant to ECC Board Resolution No. 93-08-0068 and the ECC Rules of Procedure. This effectively tolled the running of the prescriptive period. The term “funeral benefits” connotes benefits arising from death. Furthermore, the Court emphasized the constitutional guarantee of social justice and the liberal interpretation in favor of the employee in implementing social legislation like the Employees’ Compensation Act. However, since the issue of whether Mesa’s death was compensable was not fully raised or discussed below, the case was remanded to the ECC to rule on the merits of the claim.