Employees' Compensation Commission (Social Security System) v. Edmund Sanico

Summary

This case involved Edmund Sanico, a former wood filer who developed pulmonary tuberculosis and was terminated from employment on December 31, 1991. He filed a compensation claim under P.D. No. 626 on November 9, 1994, which the SSS and ECC denied as time-barred, arguing the prescriptive period ran from when his illness became manifest in September 1991. The Supreme Court reversed, establishing that the prescriptive period for disability compensation claims should be reckoned from when the employee loses earning capacity (termination date) rather than when the illness first manifests. The Court emphasized that disability compensation focuses on loss of earning capacity, not the injury itself, and mandated liberal interpretation of social legislation in favor of workers. This decision clarified the proper computation of prescriptive periods for employee compensation claims and reinforced the pro-labor stance in social security cases.