Fortunata Vda. de Hornido v. Employees' Compensation Commission

Summary

This Supreme Court case involves a widow's claim for workers' compensation benefits filed twenty-one years after her husband's work-related disability occurred. Asenciano Hornido, a public school teacher, contracted hypertension in 1965 due to strenuous teaching work, retired in 1974, and died in 1976. His widow filed for benefits in 1985. The Court ruled that since the disability occurred before the Employees' Compensation Act took effect (January 1, 1975), the claim was governed by the old Workmen's Compensation Act. However, the claim was barred by prescription under Civil Code Article 1144, which requires filing within ten years of cause of action accrual. The Court emphasized that while the State protects workers' rights, this policy cannot override the well-settled principle of prescription. The twenty-one year delay was deemed unreasonable and fatal to the claim, establishing important precedent on prescription periods for compensation claims under transitional laws.