Article 198 of the Labor Code: Disability and Death Benefits under Social Legislation

I. Overview: Article 198 of the Labor Code of the Philippines primarily addresses the provision of disability and death benefits for employees under the Employees' Compensation Program (ECP). This provision operates within the framework of Presidential Decree No. 626, as amended, which institutionalized a state insurance program for workers suffering work-related injuries, diseases, or death.

The article underscores the obligation of employers to secure their employees under the ECP and ensure access to benefits administered by the Social Security System (SSS) for private sector employees or the Government Service Insurance System (GSIS) for public sector employees.

II. Scope of Coverage:

Employees Covered:
- All employees, whether permanent, temporary, or casual, are covered, provided they are enrolled in the Employees' Compensation Program.
- It applies to employees in both the private and public sectors.
- Self-employed individuals and voluntary SSS members are excluded.
Risks Covered:
- Work-connected disability or death, arising from accidents, illnesses, or diseases during the course of employment.
- The injury or disease must be shown to have been acquired or aggravated during work.

III. Benefits under Article 198: Employees or their beneficiaries are entitled to the following benefits under the ECP:

Disability Benefits:
- Temporary Total Disability (TTD):
  - Compensation is provided during the period the employee is unable to work.
  - Benefits include a daily income benefit equivalent to 90% of the average daily salary credit (ADSC), not exceeding 120 days (extendable to 240 days for exceptional cases).
- Permanent Partial Disability (PPD):
  - Compensation for loss or impairment of body parts or functions.
  - Benefits vary depending on the specific injury and are computed based on a schedule of disabilities prescribed by the law.
- Permanent Total Disability (PTD):
  - Benefits for cases of permanent incapacity to perform gainful work.
  - Monthly pension equivalent to the employee's ADSC, subject to minimum and maximum limits.
Medical and Rehabilitation Services:
- Coverage for necessary medical, surgical, and hospital treatment, as well as rehabilitation services to restore work capacity.
- Includes prosthetics, therapy, and other medical supplies or devices.
Death Benefits:
- Provided to the primary beneficiaries (e.g., spouse, children) or secondary beneficiaries (e.g., parents) in the absence of primary beneficiaries.
- Lump-sum or monthly pension, depending on the employment contributions and ADSC.
Funeral Benefits:
- A fixed amount provided to the family or designated beneficiaries of the deceased employee for burial expenses.
- As of recent amendments, the funeral benefit is ₱30,000.00 but may vary based on prevailing regulations.

IV. Conditions for Compensation:

Causality:
- The illness, injury, or death must be work-related or aggravated by employment conditions.
- Occupational diseases listed under the ECC guidelines are presumed compensable. For unlisted diseases, proof of causation is required.
Timeliness:
- Notice of injury or illness must be reported to the employer within five (5) days from occurrence. Failure to report may bar claims unless justified.
Good Faith:
- Claims must not be fraudulent or intended to deceive. Misrepresentation can result in denial or penalties.

V. Administration and Claims Process:

Responsible Agencies:
- The Employees’ Compensation Commission (ECC) oversees policy formulation and implementation.
- The SSS administers benefits for private-sector employees, while the GSIS administers benefits for government employees.
Filing of Claims:
- Claims for disability or death benefits must be filed with the SSS or GSIS, supported by appropriate documentation, including medical reports and employment records.
Adjudication and Appeals:
- Denied claims may be appealed to the ECC and subsequently to the Court of Appeals or Supreme Court as necessary.

VI. Employer Obligations:

Registration and Contributions:
- Employers must register employees under the SSS or GSIS and remit contributions for ECP coverage.
- Failure to register deprives the employer of the right to contest claims and makes them directly liable for benefits.
Workplace Safety:
- Employers must maintain safe working conditions to prevent occupational injuries or diseases.
- Non-compliance with safety standards may result in administrative or criminal liability.

VII. Limitations and Prohibitions:

Exclusive Remedy Rule:
- ECP benefits are the exclusive remedies for work-related disability or death, precluding civil claims unless due to gross negligence or intentional harm by the employer.
No Duplication of Benefits:
- Employees cannot claim compensation under both ECP and regular social insurance for the same contingency.
Prescriptive Period:
- Claims must be filed within three (3) years from the date of injury, illness, or death, beyond which the right to compensation is barred.

VIII. Recent Amendments and Jurisprudence:

Updates on Benefit Amounts:
- Recent increases in funeral and disability benefit rates reflect adjustments to inflation and cost-of-living changes.
Landmark Cases:
- GSIS v. De Leon (2016): Clarified that aggravation of a pre-existing condition may render it compensable.
- ECC v. Sanico (2019): Emphasized strict compliance with the causality requirement for unlisted occupational diseases.

IX. Conclusion: Article 198 ensures the welfare of employees through disability and death benefits under the Employees' Compensation Program. Its provisions reflect the state’s commitment to protect workers and their dependents from the adverse effects of employment-related risks, balancing the needs of employees with the responsibilities of employers. Proper understanding and implementation are crucial for safeguarding the rights and obligations under this critical aspect of labor law.