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Prof. Joselito Guianan Chan's The Labor Code of the Philippines, Annotated Labor Standards & Social Legislation Volume I of a 3-Volume Series 2019 Edition (3rd Revised Edition)
 

 
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UNITED STATES SUPREME COURT JURISPRUDENCE
 

 
PHILIPPINE SUPREME COURT JURISPRUDENCE
 

   
April-2003 Jurisprudence                 

  • A.C. No. 4984 April 1, 2003 - JULITO D. VITRIOLO, ET AL. v. FELINA DASIG

  • A.M. No. MTJ-03-1485 April 1, 2003 - FIDEL ISIP, JR. v. VALENTINO B. NOGOY

  • A.M. Nos. P-02-1620, P-02-1621, P-02-1622 & P-96-1194 April 1, 2003 - MELINDA F. PIMENTEL v. PERPETUA SOCORRO M. DE LEOZ

  • A.M. No. P-02-1643 April 1, 2003 - DIMAS ABALDE v. ANTONIO ROQUE

  • G.R. No. 137782 April 1, 2003 - PEOPLE OF THE PHIL. v. ARTURO R. NICOLAS

  • G.R. No. 138470 April 1, 2003 - PEOPLE OF THE PHIL. v. ARTEMIO GARCIA

  • G.R. No. 143084 April 1, 2003 - PEOPLE OF THE PHIL. v. JOSE TORELLOS

  • G.R. No. 148635 April 1, 2003 - MARILLA MAYANG CAVILE, ET AL. v. HEIRS OF CLARITA CAVILE, ET AL.

  • G.R. No. 149453 April 1, 2003 - PEOPLE OF THE PHIL., ET AL. v. PANFILO M. LACSON

  • A.M. No. 01-1-13-RTC April 2, 2003 - RE: Report on the Examination of the Cash and Accounts

  • A.M. No. P-02-1545 April 2, 2003 - ZENAIDA C. GUTIERREZ, ET AL. v. RODOLFO V. QUITALIG

  • G.R. No. 139412 April 2, 2003 - PEOPLE OF THE PHIL. v. RONALD CASTILLANO, ET AL.

  • G.R. Nos. 149028-30 April 2, 2003 - PEOPLE OF THE PHIL. v. ARMANDO CABALLERO, ET AL.

  • G.R. No. 149893 April 2, 2003 - PEOPLE OF THE PHIL. v. MELCHOR RABAGO

  • A.C. No. 4958 April 3, 2003 - FIDEL D. AQUINO v. OSCAR MANESE

  • A.M. No. MTJ-02-1436 April 3, 2003 - JAIME C. TARAN v. JOSE S. JACINTO

  • A.M. No. P-02-1595 April 3, 2003 - TIMOTEO M. CASANOVA, JR. v. FELIZARDO P. CAJAYON

  • A.M. No. P-02-1650 April 3, 2003 - ZENAIDA REYES-MACABEO v. FLORITO EDUARDO V. VALLE

  • G.R. Nos. 111098-99 April 3, 2003 - PEOPLE OF THE PHIL. v. PIO BISO

  • G.R. Nos. 143976 & 145846 April 3, 2003 - SPS. OSCAR and HAYDEE BADILLO v. ARTURO G. TAYAG, ET AL.

  • G.R. No. 144444 April 3, 2003 - STATE INVESTMENT TRUST v. DELTA MOTORS CORP.

  • G.R. No. 150978 April 3, 2003 - POWTON CONGLOMERATE v. JOHNNY AGCOLICOL

  • G.R. No. 155875 April 3, 2003 - AGAPITO CRUZ FIEL, ET AL. v. KRIS SECURITY SYSTEMS, INC., ET AL.

  • A.M. No. MTJ-03-1482 April 4, 2003 - ILUMINADA SANTILLAN VDA. DE NEPOMUCENO v. NICASIO V. BARTOLOME

  • A.M. No. P-03-1690, MTJ-01-1363 & 01-12-02-SC April 4, 2003 - ESTRELLITA M. PAAS v. EDGAR E. ALMARVEZ

  • G.R. No. 108405 April 4, 2003 - JAIME D. VIERNES, ET AL. v. N;RC, ET AL.

  • G.R. No. 117020 April 4, 2003 - VIRON TRANSPORTATION CO. v. COURT OF APPEALS, ET AL.

  • G.R. No. 125938 April 4, 2003 - PEOPLE OF THE PHIL. v. JOEL JANSON, ET AL.

  • G.R. No. 140756 April 4, 2003 - PEOPLE OF THE PHIL. v. JUAN GONZALES ESCOTE, ET AL.

  • G.R. No. 141631 April 4, 2003 - PEOPLE OF THE PHIL. v. FERDINAND FRANCISCO

  • G.R. No. 143135 April 4, 2003 - REPUBLIC OF THE PHIL. v. DAMAYAN NG PUROK 14, INC.

  • G.R. No. 143779 April 4, 2003 - FRANCISCA L. MARQUEZ v. SIMEON BALDOZ

  • G.R. Nos. 145309-10 April 4, 2003 - PEOPLE OF THE PHIL. v. VIRGILIO FLORES

  • G.R. Nos. 144476 & 144629 April 8, 2003 - ONG YONG, ET AL. v. DAVID. S. TIU, ET AL.

  • G.R. No. 149022 April 8, 2003 - CARMENCITA D. CORONEL v. ANIANO A. DESIERTO, ET AL.

  • A.M. No. MTJ-02-1428 April 9, 2003 - ARFRAN L. QUIÑONES v. FRANCISCO H. LOPEZ

  • A.M. No. P-02-1580 April 9, 2003 - RENE ESPINA v. JUAN A. GATO

  • A.M. No. RTJ-01-1630 April 9, 2003 - HEINZ R. HECK v. ANTHONY E. SANTOS

  • G.R. No. 119255 April 9, 2003 - TOMAS K. CHUA v. COURT OF APPEALS, ET AL.

  • G.R. No. 126968 April 9, 2003 - RICARDO BALUNUECO v. COURT OF APPEALS, ET AL.

  • G.R. No. 128568 April 9, 2003 - SPS. REYNALDO and ESMERALDA ALCARAZ v. PEDRO M. TANGGA-AN, ET AL.

  • G.R. No. 132371 April 9, 2003 - PEOPLE OF THE PHIL. v. DANILO Q. SIMBAHON

  • G.R. No. 133003 April 9, 2003 - PEOPLE OF THE PHIL. v. LAWRENCE MACAPANPAN, ET AL.

  • G.R. No. 141258 April 9, 2003 - TOMASA SARMIENTO v. SPS. LUIS & ROSE SUN-CABRIDO ET AL.

  • G.R. Nos. 141314 & 141369 April 9, 2003 - REPUBLIC OF THE PHIL. REPRESENTED BY ENERGY REGULATORY BOARD v. MERALCO

  • G.R. No. 143004 April 9, 2003 - PEOPLE OF THE PHIL. v. DANTE CLIDORO

  • G.R. No. 143432 April 9, 2003 - PEOPLE OF THE PHIL. v. TERENCIO L. FUNESTO

  • G.R. No. 146034 April 9, 2003 - PEOPLE OF THE PHIL. v. LASTIDE A. SUBE, ET AL.

  • G.R. No. 146815 April 9, 2003 - HEIRS OF PEDRO, ET AL. v. STERLING TECHNOPARK III ET AL.

  • G.R. No. 147468 April 9, 2003 - SPS. EDUARDO & JOSEFINA DOMINGO v. LILIA MONTINOLA ROCES, ET AL.

  • G.R. No. 147745 April 9, 2003 - MARIA BUENA OBRA v. SOCIAL SECURITY SYSTEM

  • G.R. No. 148727 April 9, 2003 - SPS. HERMOGENA AND JOSE ENGRESO v. NESTORIA DE LA CRUZ, ET AL.

  • G.R. No. 149038 April 9, 2003 - PHIL. AMERICAN GENERAL INSURANCE COMPANY v. PKS SHIPPING COMPANY

  • G.R. No. 149110 April 9, 2003 - NATIONAL POWER CORPORATION v. CITY OF CABANATUAN

  • G.R. No. 149422 April 10, 2003 - DEPARTMENT OF AGRARIAN REFORM v. APEX INVESTMENT AND FINANCING CORP.

  • G.R. No. 149578 April 10, 2003 - EVELYN TOLOSA v. NLRC, ET AL.

  • G.R. No. 143540 April 11, 2003 - JOEL G. MIRANDA v. ANTONIO C. CARREON, ET AL.

  • G.R. No. 148138 April 11, 2003 - PEOPLE OF THE PHIL. v. JOHNNY VIAJEDOR

  • A.M. No. P-02-1645 April 21, 2003 - GILBERT HOWARD M. ATIENZA v. JOSEPHINE V. DINAMPO

  • A.M. No. P-03-1695 April 21, 2003 - ARTEMIO H. QUIDILLA v. JUNAR G. ARMIDA

  • A.M. No. RTJ-03-1756 April 22, 2003 - AURORA S. GONZALES v. VICENTE A. HIDALGO

  • G.R. No. 127745 April 22, 2003 - FELICITO G. SANSON, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 129163 April 22, 2003 - VOLTAIRE ARBOLARIO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. Nos. 138650-58 April 22, 2003 - PEOPLE OF THE PHIL. v. IGNACIO SINORO

  • G.R. No. 140707 April 22, 2003 - NORGENE POTENCIANO, ET AL. v. DWIGHT "IKE" B. REYNOSO, ET AL.

  • G.R. No. 146942 April 22, 2003 - CORAZON G. RUIZ v. COURT OF APPEALS, ET AL.

  • G.R. No. 152329 April 22, 2003 - ALEJANDRO ROQUERO v. PHILIPPINE AIRLINES, INC.

  • A.M. No. RTJ-03-1763 April 24, 2003 - JOSE B. TIONGCO v. FLORENTINO P. PEDRONIO

  • A.M. No. RTJ-03-1770 April 24, 2003 - MELISSA E. MAÑO v. CAESAR A. CASANOVA

  • G.R. No. 123968 April 24, 2003 - URSULINA GANUELAS, ET AL. v. ROBERT T. CAWED, ET AL.

  • G.R. No. 137182 April 24, 2003 - PEOPLE OF THE PHIL. v. ABDILA L. SILONGAN, ET AL.

  • G.R. Nos. 137458-59 April 24, 2003 - PEOPLE OF THE PHIL. v. JESUS G. BATOCTOY, ET AL.

  • G.R. No. 137601 April 24, 2003 - PEOPLE OF THE PHIL. v. WINCHESTER ABUT, ET AL.

  • G.R. No. 139230 April 24, 2003 - PEOPLE OF THE PHIL. v. MANUEL DANIELA, ET AL.

  • G.R. No. 143672 April 24, 2003 - COMMISSIONER OF INTERNAL REVENUE v. GENERAL FOODS (PHILS.), INC.

  • G.R. No. 145915 April 24, 2003 - PEOPLE OF THE PHIL. v. VILMA Z. ALMENDRAS, ET AL.

  • G.R. No. 147038 April 24, 2003 - RICHARD TEH v. COURT OF APPEALS, ET AL.

  • A.M. No. MTJ-01-1370 April 25, 2003 - OFFICE OF THE COURT ADMINISTRATOR v. AGUSTIN T. SARDIDO

  • G.R. No. 118749 April 25, 2003 - SPS LORENZO and LORENZA FRANCISCO v. COURT OF APPEALS, ET AL.

  • G.R. No. 141187 April 28, 2003 - PEOPLE OF THE PHIL. v. RONNIE A. MACTAL

  • A.C. No. 5225 April 29, 2003 - SPS. WILFREDO & LYDIA BOYBOY v. VICTORIANO R. YABUT, JR.

  • A.M. No. MTJ-02-1453 April 29, 2003 - EDITHA PALMA GIL v. FRANCISCO H. LOPEZ, JR.

  • A.M. No. P-02-1615 April 29, 2003 - PEDRO MAGNAYE v. ERIBERTO R. SABAS

  • G.R. No. 119858 April 29, 2003 - EDWARD C. ONG v. COURT OF APPEALS, ET AL.

  • G.R. No. 122363 April 29, 2003 - VICTOR G. VALENCIA v. COURT OF APPEALS, ET AL.

  • G.R. No. 127002 April 29, 2003 - JEREMIAS L. DOLINO, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 135394 April 29, 2003 - JOSE V. DELA RAMA v. FRANCISCO G. MENDIOLA, ET AL.

  • G.R. No. 139841 April 29, 2003 - EMILIO C. VILLAROSA v. DEMOSTHENES L. MAGALLANES, ET AL.

  • G.R. No. 141518 April 29, 2003 - PEOPLE OF THE PHIL. v. CLARENCE ASTUDILLO, ET AL.

  • G.R. No. 142015 April 29, 2003 - RURAL BANK OF STA. IGNACIA v. PELAGIA DIMATULAC

  • G.R. No. 147230 April 29, 2003 - PEOPLE OF THE PHIL. v. REYNALDO R. REMERATA

  • G.R. No. 150656 April 29, 2003 - MARGARITA ROMUALDEZ-LICAROS v. ABELARDO B. LICAROS

  • A.C. No. 4724 April 30, 2003 - GORETTI ONG v. JOEL M. GRIJALDO

  • A.M. No. CA-99-9-P April 30, 2003 - MAGTANGGOL GABRIEL v. VIRGINIA C. ABELLA, ET AL.

  • A.M. No. P-00-1445 April 30, 2003 - MEDARDO M. PADUA v. IRENEO S. PAZ

  • A.M. No. P-02-1599 April 30, 2003 - LEANDRO T. LOYAO v. MAMERTO J. CAUBE, ET AL.

  • A.M. No. P-02-1600 April 30, 2003 - DOMINADOR. AREVALO, ET AL. v. EDGARDO S. LORIA, ET AL.

  • A.M. No. P-03-1696 April 30, 2003 - CIVIL SERVICE COMMISSION v. ZENAIDA T. STA. ANA

  • A.M. RTJ No. 03-1761 April 30, 2003 - JOSE B. CUSTODIO v. JESUS V. QUITAIN

  • A.M. No. RTJ-03-1775 April 30, 2003 - ISAGANI A. CRUZ v. PHILBERT I. ITURRALDE

  • A.M. No. RTJ-03-1779 April 30, 2003 - JOVENCITO R. ZUÑO, ET AL. v. ARNULFO G. CABREDO

  • G.R. Nos. 107789 & 147214 April 30, 2003 - REPUBLIC OF THE PHIL. v. SANDIGANBAYAN ET AL.

  • G.R. No. 116326 April 30, 2003 - PEOPLE OF THE PHIL. v. ROBERT LEE, ET AL.

  • G.R. No. 121211 April 30, 2003 - PEOPLE OF THE PHIL. v. RONETO DEGAMO

  • G.R. No. 121637 April 30, 2003 - PEOPLE OF THE PHIL. v. EDGARDO GREFALDIA

  • G.R. No. 125761 April 30, 2003 - SALVADOR P. MALBAROSA v. COURT OF APPEALS, ET AL.

  • G.R. No. 126568 April 30, 2003 - QUIRINO GONZALES LOGGING CONCESSIONAIRE, ET AL. v. COURT OF APPEALS, ET AL.

  • G.R. No. 126911 April 30, 2003 - PHIL. DEPOSIT INSURANCE CORP. v. COURT OF APPEALS, ET AL.

  • G.R. No. 127141 April 30, 2003 - SPS. EMMANUEL and MELANIE LANTIN v. COURT OF APPEALS, ET AL.

  • G.R. No. 128378 April 30, 2003 - PEOPLE OF THE PHIL. v. ROBERT GOMEZ, ET AL.

  • G.R. No. 128512 & 128963 April 30, 2003 - DARIO P. BELONGHILOT v. RTC OF ZAMBOANGA DEL NORTE

  • G.R. No. 129090 April 30, 2003 - RICARDO B. GONZALES v. COURT OF APPEALS, ET AL.

  • G.R. No. 129895 April 30, 2003 - PEOPLE OF THE PHIL. v. ARMANDO C. DALAG

  • G.R. No. 134940 April 30, 2003 - PEOPLE OF THE PHIL. v. CATALINO MELENDRES

  • G.R. No. 138266 April 30, 2003 - PEOPLE OF THE PHIL. v. PEDRO CABRERA, JR.

  • G.R. No. 139876 April 30, 2003 - WILLIAM TIU and/or THE ROUGH RIDERS v. JULIO PASAOL, ET AL.

  • G.R. No. 140753 April 30, 2003 - BENJAMIN S. SANTOS v. ELENA VELARDE, ET AL.

  • G.R. No. 141375 April 30, 2003 - MUNICIPALITY OF KANANGA v. FORTUNITO L. MADRONA, ET AL.

  • G.R. No. 142435 April 30, 2003 - ESTELITA BURGOS LIPAT, ET AL. v. PACIFIC BANKING CORP., ET AL.

  • G.R. No. 142591 April 30, 2003 - JOSEPH CHAN, ET AL. v. BONIFACIO S. MACEDA

  • G.R. Nos. 144445-47 April 30, 2003 - PEOPLE OF THE PHIL. v. GENARO BIONG

  • G.R. No. 146099 April 30, 2003 - PEOPLE OF THE PHIL. v. JIMMEL SANIDAD, ET AL.

  • G.R. No. 146481 April 30, 2003 - ARTURO G. RIMORIN, SR. v. PEOPLE OF THE PHIL.

  • G.R. Nos. 146685-86 April 30, 2003 - PEOPLE OF THE PHIL. v. BENJAMIN M. HILET

  • G.R. Nos. 146862-64 April 30, 2003 - PEOPLE OF THE PHIL. v. GAUDENCIO D. UMBAÑA

  • G.R. No. 146886 April 30, 2003 - DEVORAH E. BARDILLON v. BARANGAY MASILI of Calamba, Laguna

  • G.R. No. 146923 April 30, 2003 - BANK OF THE PHILIPPINE ISLANDS v. COURT OF APPEALS, ET AL.

  • G.R. No. 147033 April 30, 2003 - PEOPLE OF THE PHIL. v. MARIO UMAYAM

  • G.R. Nos. 148394-96 April 30, 2003 - PEOPLE OF THE PHIL. v. ROGER ELIARDA

  • G.R. No. 150179 April 30, 2003 - HEIRS OF WILLIAM SEVILLA, ET AL. v. LEOPOLDO SEVILLA, ET AL.

  • G.R. Nos. 150820-21 April 30, 2003 - SPS. ANTONIO and GENOVEVA BALANON-ANICETE, ET AL. v. PEDRO BALANON

  • G.R. No. 154037 April 30, 2003 - IN THE MATTER OF THE PETITION FOR HABEAS CORPUS OF BENJAMIN VERGARA, ET AL.

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    G.R. No. 147745   April 9, 2003 - MARIA BUENA OBRA v. SOCIAL SECURITY SYSTEM

     
    PHILIPPINE SUPREME COURT DECISIONS

    THIRD DIVISION

    [G.R. No. 147745. April 9, 2003.]

    MARIA BUENA OBRA, Petitioner, v. SOCIAL SECURITY SYSTEM (Jollar Industrial Sales and Services Inc.), Respondent.

    D E C I S I O N


    PUNO, J.:


    On appeal is the Decision 1 of the Court of Appeals in CA-G.R. SP No. 60704 dated September 27, 2000 sustaining the Decision 2 of the Employees’ Compensation Commission dated April 13, 2000, as well as its subsequent Resolution 3 dated March 6, 2001 denying petitioner’s Motion for Reconsideration.chanrob1es virtua1 1aw 1ibrary

    The facts of the case are as follows:chanrob1es virtual 1aw library

    Juanito Buena Obra, husband of petitioner, worked as a driver for twenty-four (24) years and five (5) months. His first and second employers were logging companies. Thereafter, he was employed at Jollar Industrial Sales and Services Inc. as a dump truck driver from January 1980 to June 1988. He was assigned to the following projects: 4

    1. January 1980 to December 1981 — F.F. Cruz Project, Nabua, Camarines Sur — hauling/delivery of filling materials from quarry to job site

    2. January 1982 to December 1983 — F.F. Cruz, 300 MW Coal Fire Thermal Plant, Calaca, Bacungan and Makban Geothermal Plant, Los Baños, Laguna — hauling/delivery of filling materials from quarry to job site

    3. January 1984 to December 1985 — Dizon Copper Silver Mines, Pili, San Marcelino, Zambales — hauling/delivery filling materials from quarry to job site

    4. January 1986 to June 1988 — Metro Manila Hauling Project

    On 27 June 1988, Juanito suffered a heart attack while driving a dump truck inside the work compound, and died shortly thereafter. In the Report of Death 5 submitted by his employer to the Social Security System (SSS), Juanito expired at the Worker’s Quarters at 10:30 a.m., of Myocardial Infarction.

    Petitioner Maria M. Buenaobra immediately filed her claim for death benefits under the SSS law. She started receiving her pension in November 1988. Petitioner was, however, unaware of the other compensation benefits due her under Presidential Decree No. 626, as amended, or the Law on Employees’ Compensation. In September 1998, or more than ten (10) years after the death of her husband, that she learned of the benefits under P.D. No. 626 through the television program of then broadcaster Ted Failon who informed that one may claim for Employees Compensation Commission (ECC) benefits if the spouse died while working for the company. Petitioner prepared the documents to support her claim for ECC benefits. On 23 April 1999, she filed with the SSS her claim for funeral benefits under P.D. No. 626, as amended, which was docketed as SSS # 04-0089326-0. 6

    On 28 July 1999, the SSS denied the claim of petitioner for funeral benefits ruling that the cause of death of Juanito was not work-connected, absent a causal relationship between the illness and the job. Caridad R. Borja, Assistant Vice-President National Capital Region (AVP — NCR) Central of the SSS Member Assistance Center in Quezon City wrote:jgc:chanrobles.com.ph

    "Please be informed that funeral claim under the Employees Compensation is hereby denied. Per medical evaluation, cause of death of subject member’s (sic) cannot be considered work connected since there is no causal relationship between the illness and the job."cralaw virtua1aw library

    On 8 October 1999, petitioner wrote to Atty. Teofilo E. Hebron, Executive Director of the ECC, appealing the denial of her claim. On 11 November 1999, Atty. Hebron ordered Dr. Simeon Z. Gonzales, Assistant Vice-President (AVP) of the Medical Services Group of the SSS to review the claim of petitioner.

    On 23 November 1999, the Medical Services Group through Dr. Perla A. Taday, AVP for Medical Operations, concluded its re-evaluation and affirmed the denial of petitioner’s claim. It reiterated that "there is no causal relationship between the cause of death/illness and member’s job as dump truck driver." 7 Pursuant to Section 5, Rule XVIII of the Implementing Rules of PD 626, the records of the deceased Juanito were elevated to the Commission.

    On 13 April 2000, the Commission rendered a decision, dismissing the appeal. 8 It ruled that petitioner failed to show by substantial evidence that her husband’s cause of death was due to, or the risk of contracting his ailment was increased by his occupation and working conditions, as per Section 1(b), Rule III of P.D. No. 626, as amended. In addition, the Commission declared that petitioner’s claim has prescribed, citing ECC Resolution No. 93-08-0068.

    Petitioner appealed to the Court of Appeals. She alleged that her cause of action had not prescribed because the filing of her claim for SSS benefits shortly after Juanito’s death suspended the running of the prescriptive period for filing EC claims, as per Item No. III of ECC Resolution No. 90-03-0022 dated 23 March 1990. The appellate court dismissed the petition. It ruled that petitioner’s filing of her claim for SSS benefits shortly after Juanito’s death did not suspend the running of the prescriptive period for filing EC claims. It interpreted the aforementioned ECC Resolutions to mean that a claimant must indicate the kind of claim filed before the running of the prescriptive period for filing EC claims may be interrupted. In the case at bar, petitioner indeed filed a claim with SSS. In fact, she has been receiving her pension since November 1988. However, she failed to specify whether the basis of her claim was any contingency which may be held compensable under the EC Program. 9

    In addition, the Court of Appeals cited P.D. No. 626 which states that a contingency may be held compensable if listed in Annex "A" of the Rules Implementing Employees’ Compensation as an occupational disease, and satisfying all conditions set forth therein; or if not listed as an occupational disease, or listed but has not satisfied the conditions set forth therein, it must be proven by substantial evidence that the risk of contracting the disease which caused the death of the member, was increased by the member’s working conditions. 10

    The appellate court likewise held that the three-year prescriptive period does not apply in the instant case. Instead, it applied Art. 1144(2) of the Civil Code which reads:jgc:chanrobles.com.ph

    "Art. 1144. The following actions must be brought within ten (10) years from the time the right of action accrues:chanrob1es virtual 1aw library

    (1) Upon a written contract;

    (2) Upon an obligation created by law;

    (3) Upon a judgment. [Emphasis supplied.]"

    The appellate court then held that the petitioner’s cause of action has prescribed. Petitioner’s husband died on 27 June 1988. She filed her claim for funeral benefits under P.D. No. 626 or the Law on Employees’ Compensation only on 23 April 1999, or more than ten (10) years from his death.

    Lastly, the appellate court ruled that even assuming petitioner’s cause of action has not prescribed, her claim for Employees’ Compensation benefits cannot prosper because of her failure to prove by substantial evidence that her husband’s working conditions increased the risk of contracting the myocardial infarction that caused his death.

    Petitioner’s Motion for Reconsideration dated 27 September 2000 was denied by the appellate court in a Resolution promulgated on 6 March 2001.

    Hence, this petition. The following issues are raised: 11

    (1) WHETHER, INDEED, THE CLAIM OF PETITIONER, HAD PRESCRIBED.

    (2) WHETHER OR NOT THE ILLNESS OF PETITIONER’S HUSBAND, MYOCARDIAL INFARCTION, IS WORK-RELATED.

    On the first issue, we rule that the claim of petitioner for funeral benefits under P.D. No. 626, as amended, has not yet prescribed.

    The issue of prescription in the case at bar is governed by P.D. No. 626, or the Law on Employees’ Compensation. Art. 201 of P.D. No. 626 and Sec. 6, Rule VII of the 1987 Amended Rules on Employees’ Compensation both read as follows:jgc:chanrobles.com.ph

    "No claim for compensation shall be given due course unless said claim is filed with the System within three years from the time the cause of action accrued."cralaw virtua1aw library

    This is the general rule. The exceptions are found in Board Resolution 93-08-0068 and ECC Rules of Procedure for the Filing and Disposition of Employees’ Compensation Claims. Board Resolution 93-08-0068 issued on 5 August 1993, states:jgc:chanrobles.com.ph

    "A claim for employee’s compensation must be filed with System (SSS/GSIS) within three (3) years from the time the cause of action accrued, provided however, that any claim filed within the System for any contingency that may be held compensable under the Employee’s Compensation Program (ECP) shall be considered as the EC claim itself. The three-year prescriptive period shall be reckoned from the onset of disability, or date of death. In case of presumptive death, the three (3) years limitation shall be counted from the date the missing person was officially declared to be presumptively dead." (Emphasis supplied)

    In addition, Section 4(b), Rule 3 of the ECC Rules of Procedure for the Filing and Disposition of Employees’ Compensation Claims, reads:jgc:chanrobles.com.ph

    "RULE 3. FILING OF CLAIM

    Section 4. When to file.

    (a) Benefit claims shall be filed with the GSIS or the SSS within three (3) years from the date of the occurrence of the contingency (sickness, injury, disability or death).

    (b) Claims filed beyond the 3-year prescriptive period may still be given due course, provided that:chanrob1es virtual 1aw library

    1. A claim was filed for Medicare, retirement with disability, burial, death claims, or life (disability) insurance, with the GSIS within three (3) years from the occurrence of the contingency.

    2. In the case of the private sector employees, a claim for Medicare, sickness, burial, disability or death was filed within three (3) years from the occurrence of the contingency.

    3. In any of the foregoing cases, the employees’ compensation claim shall be filed with the GSIS or the SSS within a reasonable time as provided by law. [Emphasis supplied.]"

    We agree with the petitioner that her claim for death benefits under the SSS law should be considered as the Employees’ Compensation claim itself. This is but logical and reasonable because the claim for death benefits which petitioner filed with the SSS is of the same nature as her claim before the ECC. Furthermore, the SSS is the same agency with which Employees’ Compensation claims are filed. As correctly contended by the petitioner, when she filed her claim for death benefits with the SSS under the SSS law, she had already notified the SSS of her employees’ compensation claim, because the SSS is the very same agency where claims for payment of sickness/disability/death benefits under P.D. No. 626 are filed.

    Section 4(b)(2), Rule 3 of the ECC Rules of Procedure for the Filing and Disposition of the Employees’ Compensation Claims, quoted above, also provides for the conditions when EC claims filed beyond the three-year prescriptive period may still be given due course. Section 4(b)(2) states the condition for private sector employees, requiring that a claim for Medicare, sickness, burial, disability or death should be filed within three (3) years from the occurrence of the contingency. In the instant case, the petitioner was able to file her claim for death benefits under the SSS law within the three-year prescriptive period. In fact, she has been receiving her pension under the SSS law since November 1988.

    It is true that under the proviso, the employees’ compensation claim shall be filed with the GSIS/SSS within a reasonable time as provided by law. It should be noted that neither statute nor jurisprudence has defined the limits of "reasonable time." Thus, what is reasonable time depends upon the peculiar facts and circumstances of each case. 12 In the case at bar, we also find petitioner’s claim to have been filed within a reasonable time considering the situation and condition of the petitioner. We have ruled that when the petitioner filed her claim for death benefits under the SSS law, her claim for the same benefits under the Employees’ Compensation Law should be considered as filed. The evidence shows that the System failed to process her compensation claim. Under the circumstances, the petitioner cannot be made to suffer for the lapse committed by the System. It is the avowed policy of the State to construe social legislations liberally in favor of the beneficiaries. 13 This court has time and again upheld the policy of liberality of the law in favor of labor. Presidential Decree No. 626 itself, in its Art. 166 reads:jgc:chanrobles.com.ph

    "ART. 166. Policy. — The State shall promote and develop a tax-exempt employees’ compensation program whereby employees and their dependents, in the event of work-connected disability or death, may promptly secure adequate income benefit, and medical or related benefits." (Emphasis supplied)

    Furthermore, Art. 4 of P.D. No. 442, as amended, otherwise known as the Labor Code of the Philippines, which P.D. No. 626 forms a part of, reads as follows:jgc:chanrobles.com.ph

    "ART. 4. Construction in favor of labor. — All doubts in the implementation and interpretation of the provisions of this Code, including its implementing rules and regulations, shall be resolved in favor of labor."cralaw virtua1aw library

    Particularly, the policy of liberality in deciding claims for compensability was given emphasis by this court in the case of Employees’ Compensation Commission v. Court of Appeals, 14 where it held that:jgc:chanrobles.com.ph

    ". . . the liberality of law in favor of the working man and woman still prevails and the official agency charged by law to implement the constitutional guarantee of social justice should adopt a liberal attitude in favor of the employee in deciding claims for compensability, especially in light of compassionate policy towards labor which the 1987 Constitution vivifies and enhances. Elsewise stated, a humanitarian impulse, dictated by no less than the Constitution itself under the social justice policy, calls for a liberal and sympathetic approach to legitimate appeals of disabled public servants; or that all doubts to the right to compensation must be resolved in favor of the employee or laborer. Verily the policy is to extend the applicability of the law on employees’ compensation to as many employees who can avail of the benefits thereunder." chanrob1es virtua1 1aw 1ibrary

    Claims falling under the Employees’ Compensation Act should be liberally resolved to fulfill its essence as a social legislation designed to afford relief to the working man and woman in our society. 15

    The second issue of whether or not the illness of petitioner’s husband, myocardial infarction which was the cause of his death is work-related, must likewise be resolved in favor of the petitioner.

    Under the law on employees’ compensation, death is compensable only when it results from a work-connected injury or sickness. In the instant case, the cause of petitioner’s husband’s death was myocardial infarction and it must be considered work-connected. While it is true that myocardial infarction is not among the occupational diseases listed under Annex "A" of the Amended Rules on Employees’ Compensation, the Commission, under ECC Resolution No. 432 dated July 20, 1977, laid down the conditions under which cardio-vascular or heart diseases can be considered as work-related and thus compensable, viz:chanrob1es virtual 1aw library

    (a) If the heart disease was known to have been present during employment, there must be proof that an acute exacerbation was clearly precipitated by the unusual strain by reasons of the nature of his/her work.

    (b) The strain of work that brings about an acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship.

    (c) If a person who was apparently asymptomatic before being subjected to strain at work showed signs and symptoms of cardiac injury during the performance of his/her work and such symptoms and signs persisted, it is reasonable to claim a causal relationship.

    Myocardial infarction is also known as heart attack. It results in permanent heart damage or death. A heart attack is called myocardial infarction because part of the heart muscle (myocardium) may literally die (infarction). This occurs when a blood clot blocks one of the coronary arteries (the blood vessels that bring blood and oxygen to the heart muscle). When the heart muscle does not obtain the oxygen-rich blood that it needs, it will begin to die. The severity of a heart attack usually depends on how much of the heart muscle is injured or dies during the heart attack. Heart attack accounts for 1 out of every 5 deaths. It is a major cause of sudden death in adults. Heavy exertion or emotional stress can trigger a heart attack. 16

    In the case at bar, the petitioner’s husband’s heart disease falls under the second condition of ECC Resolution No. 432 dated July 20, 1977 which states that the strain of work that brought about the acute attack must be of sufficient severity and must be followed within 24 hours by the clinical signs of a cardiac insult to constitute causal relationship. Petitioner’s husband was driving a dump truck within the company premises where they were stacking gravel and sand when he suffered the heart attack. He had to be taken down from the truck and brought to the workers’ quarters where he expired at 10:30 a.m., just a few minutes after the heart attack, which is much less than the 24 hours required by ECC Resolution No. 432. This is a clear indication that severe strain of work brought about the acute attack that caused his death.

    Professional drivers, especially truck drivers like the decedent in the instant case, carry the burden of being more exposed and subjected to the stress and strain of everyday traffic, and the greater physical exertion brought about by driving a large and heavy vehicle. In addition, according to the petitioner, her husband was under a lot of stress in the workplace. He was a model worker and his employer highly depended on him. He became the object of envy of his co-workers which caused him much emotional stress. Add to this the fact that he has been a truck driver for more than twenty-four (24) years. Due to the combination of emotional stress and vigorous physical exertion, it was easy for him to succumb to the heart ailment. We hold that the illness of the decedent which caused his death is work-connected, and thus compensable by virtue of ECC Resolution No. 432 dated 20 July 1977.

    As a final note, we find it necessary to reiterate 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 the official agents charged by law to implement social justice guaranteed by the Constitution, the ECC and the SSS 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 illness or injury, as the case may be. It is only this kind of interpretation that can give 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. 17

    IN VIEW WHEREOF, the petition is GRANTED. The Decision of the Court of Appeals in CA-G.R. SP No. 60704 dated 27 September 2000 and its Resolution dated 06 March 2001 are hereby SET ASIDE. The SSS is hereby directed to pay herein petitioner the death/funeral benefits due him under the existing law.chanrob1es virtua1 1aw 1ibrary

    SO ORDERED.

    Panganiban, Sandoval-Gutierrez, Corona and Carpio-Morales, JJ., concur.

    Endnotes:



    1. Rollo, pp. 121–128.

    2. Id. at 110–117.

    3. Id. at 189.

    4. CA Rollo, p. 26.

    5. Id. at 33.

    6. Id., at 39.

    7. Id. at 46.

    8. Id. at 51.

    9. Rollo, p. 125.

    10. Id., p. 126, citing Employees Compensation Commission v. CA, 264 SCRA 248.

    11. Id. at 18.

    12. Far East Realty Investment, Inc. v. Court of Appeals, G.R. No. L-36549, 05 October 1988.

    13. Government Service Insurance System v. Court of Appeals, G.R. No. 132648, 04 March 1999.

    14. G.R. No. 121545, 14 November 1996, 264 SCRA 248, citing Nitura v. Employees’ Compensation Commission, 201 SCRA 278, Aris (Phils.), Inc. v. NLRC, 200 SCRA 246, and Diopenes v. GSIS, 205 SCRA 331.

    15. Santos v. Employees’ Compensation Commission, 221 SCRA 182, 188.

    16. Lee B. Weitzman, M.D., FACC, FCCP, "Heart Attack," (2001) <http://www.heartcenteronline.com/>

    17. Nitura v. Employees’ Compensation Commission, 201 SCRA 278, 283 (1991); Santos v. Employees’ Compensation Commission, 221 SCRA 182, 188 (1993).

    G.R. No. 147745   April 9, 2003 - MARIA BUENA OBRA v. SOCIAL SECURITY SYSTEM


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