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Updated 3rd February 2025
Buena Obra vs. Social Security System
The Supreme Court ruled that Maria Buena Obra’s claim for employees’ compensation benefits for her husband’s work-related death due to myocardial infarction was not time-barred and was compensable, reversing lower court decisions that denied her claim based on prescription and lack of causal connection.

Primary Holding

The Court held that (1) the claim was filed within a “reasonable time” due to the SSS’s failure to process her EC claim earlier, and (2) myocardial infarction was work-related under ECC Resolution No. 432 due to job strain.

Background

Juanito Buena Obra, a dump truck driver for 24 years, died of a heart attack at work in 1988. His widow filed for SSS death benefits but learned about EC benefits a decade later. The SSS/ECC rejected her claim, alleging prescription and lack of work connection.

History

  • June 27, 1988: Juanito dies of myocardial infarction.

  • November 1988: Maria receives SSS pension.

  • April 23, 1999: Maria files EC claim with SSS.

  • July 28, 1999: SSS denies claim.

  • April 13, 2000: ECC dismisses appeal.

  • September 27, 2000: Court of Appeals affirms ECC.

  • March 6, 2001: CA denies reconsideration.

  • April 9, 2003: Supreme Court reverses lower courts.

Facts

  • 1. Juanito worked as a dump truck driver for 24 years, hauling materials in physically demanding projects. He suffered a fatal heart attack while driving at work. Maria filed for EC benefits 11 years later after learning about them through a TV program.

Arguments of the Petitioners

  • 1. Filing for SSS benefits suspended the EC claim’s prescriptive period
  • 2. Juanito’s job strain and stress contributed to his heart attack, making it work-related.

Arguments of the Respondents

  • 1. The claim prescribed after 10 years
  • 2. No causal link between myocardial infarction and his job since it was not listed as an occupational disease.

Issues

  • 1. Did the claim prescribe?
  • 2. Was myocardial infarction work-related?

Ruling

  • 1. The claim was timely because filing for SSS benefits interrupted the prescriptive period, and liberal interpretation favors laborers
  • 2. Myocardial infarction was compensable under ECC Resolution No. 432 due to job-related physical and emotional strain.

Doctrines

  • 1. Liberal Construction of Labor Laws: Doubts in social legislation must favor laborers.
  • 2. ECC Resolution No. 432: Cardiovascular diseases are compensable if work strain triggered the attack within 24 hours.
  • 3. Prescription Suspension: Filing SSS claims can interrupt EC prescription if filed within three years.

Key Excerpts

  • 1. “The avowed policy of the State is to construe social legislations liberally in favor of the beneficiaries.”
  • 2. “A humanitarian impulse…calls for a liberal and sympathetic approach to legitimate appeals of disabled public servants.”

Precedents Cited

  • 1. ECC v. CA (1996): Emphasized liberal interpretation for labor.
  • 2. Nitura v. ECC (1991): Reinforced resolving doubts in favor of workers.
  • 3. Santos v. ECC (1993): Upheld compensability for heart attacks under PD 626.

Statutory and Constitutional Provisions

  • 1. PD 626, Art. 201: Three-year prescriptive period for EC claims.
  • 2. ECC Rules, Rule 3, Sec. 4(b): Allows late EC claims if related benefits (e.g., SSS) were timely filed.
  • 3. Labor Code, Art. 4: Mandates labor-friendly interpretation.