Case Summary (G.R. No. 147745)
Factual Background
Juanito Buena Obra worked various projects over his employment at Jollar Industrial Sales and Services Inc. until his untimely death. Following his death, Maria Buena Obra applied for death benefits from the SSS, which she began receiving in November 1988. However, it was not until September 1998 that she learned about entitlement to additional compensation benefits under P.D. No. 626. On April 23, 1999, she filed a claim for funeral benefits, which was denied by the SSS due to the determination that her husband’s death was not work-related.
Procedural History
After the denial, Maria Buen Obra appealed to the Employees' Compensation Commission (ECC), which also dismissed her appeal, stating insufficient evidence to prove a causal relationship between Juanito's occupation and the myocardial infarction. The ECC ruled the claim had prescribed due to non-compliance with the statutory deadlines, leading to an appeal to the Court of Appeals.
Issue of Prescription of Claim
The primary issue evaluated was whether Maria Buena Obra's claim for funeral benefits had prescribed. The decision referenced the applicability of P.D. No. 626, which mandates that claims must generally be filed within three years from the cause of action's accrual. However, the ruling emphasized exceptions outlined in specific resolutions that recognize filings for other contingencies, like SSS benefits, as equivalent claims under the Employees’ Compensation framework.
Court's Ruling on Prescription
The Supreme Court ruled that the claim for funeral benefits had not prescribed, agreeing with the petitioner that her earlier claim for SSS benefits effectively notified the SSS of her intent to file for employee compensation. The Court found the nature of her SSS claim aligned with her claim for ECC benefits and highlighted that no definitions for “reasonable time” had been established in law, indicating that the specifics of the petitioner’s situation warranted a liberal interpretation of the prescriptive periods.
Work-Related Illness Determination
The second key issue concerns whether Juanito Buena Obra's myocardial infarction was work-related. It was established that an illness must be proven to be work-related for compensability under the Employees’ Compensation law. Although myocardial infarction is not explicitly listed as an occupational disease, the conditions set by ECC Resolution No. 432 provided a pathway to establish its work-relatedness.
Analysis of Causal Relationship
The Court ruled that the circumstances of Juanito's fatal heart attack met the conditions set forth in ECC Resolution No
...continue readingCase Syllabus (G.R. No. 147745)
Case Background
- The case is an appeal against the Decision of the Court of Appeals in CA-G.R. SP No. 60704 dated September 27, 2000.
- The Court of Appeals sustained the Decision of the Employees' Compensation Commission dated April 13, 2000, and its subsequent Resolution dated March 6, 2001, which denied the claim of the petitioner for funeral benefits under Presidential Decree No. 626, as amended.
- The petitioner, Maria M. Buena Obra, is the wife of Juanito Buena Obra, who worked as a driver for over 24 years.
- Juanito was employed by Jollar Industrial Sales and Services Inc. as a dump truck driver from January 1980 until his death on June 27, 1988, due to a heart attack (myocardial infarction) while on duty.
Employment History
- Juanito's employment history includes:
- Working for logging companies prior to his employment at Jollar Industrial.
- Driving dump trucks for various projects, including:
- F.F. Cruz Project in Nabua, Camarines Sur (1980-1981).
- 300 MW Coal Fire Thermal Plant and Makban Geothermal Plant (1982-1983).
- Dizon Copper Silver Mines in Zambales (1984-1985).
- Metro Manila Hauling Project (1986-1988).
Death and Initial Claim
- Juanito suffered a heart attack on June 27, 1988, and died shortly thereafter at the Worker’s Quarters.
- His death was reported to the Social Security System (SSS) as being due to myocardial infarction.
- Maria began receiving her pension in November 1988 but was unaware of additional compensation benefits available under P.D. No. 626.
Discovery of Additional Benefits
- In September 1998, Maria learned about her eligibility