Facts:

The case involves petitioner Soledad MuAoz Mesa, who filed an appeal against the Social Security System (SSS) and Philrock Incorporated. Teodoro Mesa, her husband, was employed by Philrock from April 1966 until November 1998. During the course of his employment, he was diagnosed with multiple health issues, including diabetes mellitus, pulmonary tuberculosis, and ischemic heart disease. Following a hospitalization from September 23 to 30, 1988, for which he was treated for his conditions, Teodoro Mesa continued to work until he suffered a myocardial infarction and died on November 19, 1988.

In October 2000, Soledad sought employees’ compensation benefits under the Employees’ Compensation Law (P.D. 626, as amended). The SSS denied her claim via a pro-forma letter dated January 18, 2001, on the grounds that it was filed beyond the prescriptive period. Soledad contended that her application was delayed due to her lack of knowledge about her husband's entitlement to these benef

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Facts:

Employment and Medical History

• Teodoro Mesa, the late husband of petitioner Soledad MuAoz Mesa, was employed by Philrock Incorporated from April 1966 until November 1998.
• During his employment, Mesa was diagnosed with multiple ailments:
• Diabetes mellitus
• Pulmonary tuberculosis
• Ischemic heart disease
• In September 1988, Mesa was confined at St. Martha’s Specialty Clinic in Tarlac City due to his medical conditions.
• He resumed work after his hospitalization until he ultimately succumbed to myocardial infarction on November 19, 1988, while serving as Project General Superintendent.

Filing of Claims and Subsequent Denials

• In October 2000—approximately 12 years after his death—petitioner Soledad MuAoz Mesa filed a claim for employees’ compensation benefits under Presidential Decree (P.D.) No. 626, as amended.
• The Social Security System (SSS) initially denied the claim by a pro-forma letter dated January 18, 2001 on the ground of prescription.
• Petitioner moved for reconsideration:
• She argued that her delay in filing was due to her ignorance about the compensability of her husband’s death benefits until informed by a friend.
• She further contended that her own health issues—resulting in her being frequently in and out of the hospital—contributed to the delay.
• The SSS elevated the motion to the Employees Compensation Commission (ECC) which, in its Decision dated August 24, 2001, ruled that the claim was barred:
• The ECC noted that according to Article 201 of P.D. 626, claims must be filed within three years from the time the cause of action accrued.
• Even applying Article 1144 of the Civil Code, the period from the last contingency on November 25, 1998 to the October 2000 filing amounted to nearly 12 years.

Prior Related Claims and Notices

• Petitioner had previously filed a claim for death and funeral benefits with the SSS:
• A Supplement to the Petition included an Online Inquiry System-generated "Death, Disability and Retirement Claims Information" sheet indicating a claim filed on December 12, 1988.
• Additionally, there is reference to a claim filed on November 25, 1988 which was denominated as “SSS Death and Funeral Benefit.”
• The Court of Appeals examined whether these earlier filings functioned as constructive notice toward the filing of a compensation claim under the Employees’ Compensation Law.

Proceedings Prior to the Supreme Court

• The ECC Decision and its subsequent Resolution (denying petitioner’s motion for reconsideration) were upheld by the Court of Appeals in its Decision dated January 16, 2003.
• On appeal, petitioner contended that:
• The three-year period under P.D. 626 should be viewed not strictly as a prescriptive period but rather as a procedural requirement for the exercise of a statutory right.
• The earlier filing of the death benefit claim with the SSS—despite being for funeral benefits—served as constructive notice that should toll the running of the prescriptive period.
• Social justice precepts and humanitarian considerations warrant a liberal interpretation in favor of the employee.

Issue:

Whether the petitioner’s claim for employees’ compensation benefits is time-barred by prescription given that:

• The claim for compensation benefits under P.D. 626 was filed almost 12 years after the occurrence of the contingent event.
• The applicable rule under Article 201 of P.D. 626 clearly mandates a three-year filing period.

Whether the prior filing of a claim for death and funeral benefits with the SSS on November 25, 1988 (and subsequently on December 12, 1988) qualifies as constructive notice to the ECC:

• Whether such filing effectively tolled or paused the running of the prescriptive period for the purposes of claiming employees’ compensation benefits.
• Whether the compassionate and social justice-oriented provisions embedded in the law call for a liberal interpretation in favor of employees, thereby preventing the petitioner from suffering due to procedural lapses attributable to systemic delays.

Whether, despite the issues of prescription and constructive notice, there is a need to address the compensability of Mesa’s death:

• This particular issue was not fully raised or developed in the lower tribunals, necessitating remand for a proper resolution.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)