Case Summary (G.R. No. 134028)
Relevant Medical and Employment Background
Sanico was employed as a wood filer from 1986 until he was separated from his job on December 31, 1991, due to his health condition. A medical evaluation confirmed the onset of his PTB on September 31, 1991, which was further corroborated by chest x-rays conducted in 1994. Following his separation, Sanico filed a claim for compensation benefits due to his illness on November 9, 1994.
Claims Denial and Legal Proceedings
The SSS denied Sanico's initial claim on April 23, 1996, citing prescription of the claim, based on the assertion that it was filed beyond the three-year period allowed under Article 201 of the Labor Code, which states that compensation claims must be filed within three years from the date the cause of action accrued. The SSS argued that his claim should be reckoned from the date his illness first became manifest—September 21, 1991.
Court of Appeals Reversal
Upon appeal, the Court of Appeals reversed the denial, ruling that Sanico’s claim was filed within the appropriate prescriptive period. The CA reconciled the provisions of Article 201 of the Labor Code with Article 1144(2) of the Civil Code, stating that claims associated with obligations created by law must be filed within ten years. The court determined that the crucial date for assessing the prescriptive period was not the manifestation of the illness but rather the termination of employment due to the illness on December 31, 1991.
Supreme Court’s Reasoning
The Supreme Court affirmed the ruling of the Court of Appeals, stating that the accurate reckoning for prescription should occur from the date the employee's earning capacity was genuinely impaired—marked by the termination of employment. The Court highlighted its previous rulings, clarifying that the nature of disability must focus on the incapacity to earn rather than solely on medical diagnoses.
Interpretation of Disability and Compensation
The Court reiterated that disability is not merely a medical condition; rather, it encompasses the loss of earning capacity. Consequently, it ruled that Sanico’s claim was indeed filed within the three-year window. The Court deemed it unnecessary to delve into the apparent conflict between the labor code and civil code prescriptions, as Sanico
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Case Overview
- This case involves a petition for review filed by the Employees' Compensation Commission (ECC) seeking to overturn the Court of Appeals' decision in CA G.R. SP No. 47804, which was dated 28 May 1998.
- The Court of Appeals had reversed the ECC's decision from 20 March 1997 in ECC Case No. 8342, which denied Edmund Sanico's claim for compensation benefits under Presidential Decree No. 626, as amended.
Factual Background
- Edmund Sanico was employed as a "wood filer" by John Gotamco and Sons from 1986 until his separation on 31 December 1991 due to illness.
- On 31 September 1991, a medical evaluation report confirmed that Sanico was suffering from pulmonary tuberculosis (PTB).
- Subsequent chest x-rays on 9 October 1994 and 3 May 1995 verified his condition.
- Sanico filed a claim for compensation benefits with the Social Security System (SSS) on 9 November 1994.
Procedural History
- The SSS denied Sanico’s claim on 23 April 1996, citing that the claim had prescribed under Article 201 of the Labor Code, which requires claims to be filed within three years of the cause of action accruing.
- The SSS determined that the prescriptive period began on 21 September 1991, the date when Sanico's PTB first became ma