The Employees’ Compensation Commission (ECC) granted EC disability benefits to a former private sector employee for his shoulder muscle tear, an injury that he sustained due to an accident at work. The said benefit was granted by ECC on appeal after his claim was denied by the Social Security System (SSS).

Appellant had been working as an administrative manager for a lending company. In June 2018, he informed his employer that in November 2017, while on his way to his place of work that was undergoing demolition, he accidentally stepped on a rock which caused him to fall on his left shoulder. He experienced pain and limitation of movement on his left shoulder which persisted for months.

When the employee filed an Employees’ Compensation (EC) claim, the SSS denied the claim for benefits on the ground that he failed to prove that the accident happened during working hours and while in the workplace. Another reason for the denial was the late reporting of the incident to the employer.

On appeal, the ECC resolved to grant appellant’s claim for benefits. ECC declared that in the determination of work-relatedness of the contingency, “strict rules of evidence” in not applied under the EC law otherwise known as PD 626, as amended, since the law merely requires substantial evidence.

Furthermore, while the EC law requires workers to notify their employer in case of work-related contingencies, the appellant’s accident falls under circumstances in which notice to the employer is not necessary, in as much as the incident occurred within the employer’s premises and while in the performance of his work.

With this decision, the ECC remains consistent with the Labor Code’s provision to resolve claims for compensation benefits in favor of labor.


J. Romasanta – REU 4A / I. Yumang – REU 7