G.R. No. 175888 - Nicolas y Sombilon vs. Romulo

Juanito Buena Obra, husband of the petitioner Maria M. Buena Obra, served as a driver for over twenty-four years and five months.
His early employment was with logging companies, after which he worked at Jollar Industrial Sales and Services Inc. as a dump truck driver from January 1980 until June 1988.
During his tenure at Jollar Industrial Sales and Services Inc., he was assigned to various projects:

(January 1980 to December 1981) F.F. Cruz Project in Nabua, Camarines Sur – hauling/delivery of filling materials from quarry to job site.
(January 1982 to December 1983) F.F. Cruz project involving a 300 MW Coal Fire Thermal Plant in Calaca, Bacungan and Makban Geothermal Plant in Los Baños, Laguna – again, focused on hauling/delivery of filling materials from quarry to job site.
(January 1984 to December 1985) Dizon Copper Silver Mines located in Pili, San Marcelino, Zambales – involved in hauling/delivery of filling materials.
(January 1986 to June 1988) A Metro Manila Hauling Project.

On 27 June 1988, while on duty inside the work compound driving a dump truck, Juanito suffered a heart attack (myocardial infarction).
He was attended immediately and brought to the workers’ quarters where he expired shortly after at 10:30 a.m.
The Report of Death, submitted by his employer to the Social Security System (SSS), formally recorded myocardial infarction as the cause of death.

Immediately following his death, petitioner Maria M. Buena Obra filed a claim for death benefits under the SSS law and began receiving her pension starting November 1988.
Unaware at the time of other compensatory benefits under Presidential Decree (P.D.) No. 626 (as amended) and the Employees’ Compensation Law, she later discovered through a television program (by broadcaster Ted Failon in September 1998) that additional benefits might be claimable under the Employees’ Compensation Commission (ECC).
In response, petitioner's documents were prepared and she subsequently filed her claim for funeral benefits on 23 April 1999 with the SSS. This claim was docketed as SSS #04-0089326-0.

On 28 July 1999, the SSS denied the petitioner’s claim for funeral benefits based on the finding that there was no causal relationship between Juanito’s illness (myocardial infarction) and his job duties as a dump truck driver.
A resolution by Caridad R. Borja, Assistant Vice-President of the National Capital Region (AVP a NCR) Central of the SSS Member Assistance Center, explicitly stated that the funeral claim under the Employees’ Compensation Program was denied due to the absence of work connection.
Subsequently, the petitioner appealed this decision by writing to Atty. Teofilo E. Hebron, Executive Director of the ECC, on 8 October 1999.
A re-evaluation was ordered on 11 November 1999 by Atty. Hebron, and on 23 November 1999, the Medical Services Group, through Dr. Perla A. Taday, AVP for Medical Operations, reaffirmed the denial of the claim, maintaining that there was no evidence to establish a causal connection between Juanito’s illness and his employment.

Under Section 5, Rule XVIII of the Implementing Rules of P.D. No. 626, Juanito’s records were forwarded to the Commission.
On 13 April 2000, the ECC rendered a decision dismissing the petitioner’s appeal on two main grounds:

Failure to show by substantial evidence that Juanito’s cause of death was due to or had an increased risk by virtue of his work conditions.
The claim was declared to have prescribed based on ECC Resolution No. 93-08-0068.

The petitioner further appealed this decision to the Court of Appeals, contending that her earlier filing for death benefits under the SSS should have effectively suspended the prescriptive period applicable to EC claims.
The Court of Appeals, however, dismissed her appeal:

It ruled that filing the death benefits claim with the SSS did not interrupt the running of the prescriptive period because her claim did not specify that it was based on an EC contingency.
It held that since her husband died on 27 June 1988 and the funeral benefits claim was only filed on 23 April 1999 – well beyond the prescribed period – the action was time-barred.
Additionally, even if the claim was not deemed prescribed, the petitioner failed to prove by substantial evidence that her husband’s working conditions increased the risk of his myocardial infarction.

Whether the petitioner’s claim for funeral (or death) benefits under P.D. No. 626 had prescribed, given that it was filed more than ten years after the death of her husband.
The argument centered on whether the earlier filing of death benefits under the SSS law should be regarded as an interruption or suspension of the prescriptive period for filing Employees’ Compensation claims.

Whether the myocardial infarction that caused the death of Juanito Buena Obra should be considered work-related.
This issue examined if there was a causal relationship between the decedent’s job as a dump truck driver – with its inherent physical and emotional strains – and his heart attack, taking into account the conditions set forth in ECC Resolution No. 432 regarding work-related cardiac events.