LABOR LAW COURSE AUDIT

2024

Private Government SME/Self-Employed

ATTY. REYCHELLE R. ARIMADO, CPA
WAGE DISTORTION – LABOR CODE, ART. 124
Wage Distortion - shall mean a situation where an increase in
prescribed wage rates results in the elimination or severe contraction of
intentional quantitative differences in wage or salary rates between and
among employee groups in an establishment as to effectively obliterate
the distinctions embodied in such wage structure based on skills, length
of service, or other logical bases of differentiation.
MINIMUM WAGE – LABOR CODE, ART. 99
The minimum wage rates for agricultural
and non-agricultural employees and
workers in each and every region of the
country shall be those prescribed by the
Regional Tripartite Wages and Productivity
Boards.
OMNIBUS RULES IMPLEMENTING THE LABOR
CODE, BOOK III, RULE VII, SECS. 7, 9 AND 15
SECTION 7 Basis of Minimum
Wages Rates. — The statutory
minimum wage rules prescribed
under the Act shall be for the
normal working hours, which
shall not exceed eight hours
work a day.
OMNIBUS RULES IMPLEMENTING THE LABOR
CODE, BOOK III, RULE VII, SECS. 7, 9 AND 15
SECTION 9 Workers Paid by Results
a) All workers paid by results, including
those who are paid on piecework, takay,
pakyaw, or task basis, shall receive not
less than the applicable statutory
minimum wage rates prescribed under the
Act for the normal working hours which
shall not exceed eight hours work a day,
or a proportion thereof for work of less
than the normal working hours.
OMNIBUS RULES IMPLEMENTING THE LABOR
CODE, BOOK III, RULE VII, SECS. 7, 9 AND 15
SECTION 15. Exemptions
a) The following establishments may be
exempted from compliance with the wage
increase prescribed under the Act:

1) Retail/Service establishments regularly

employing not more than 10 workers
upon application with and as determined
by the appropriate Board in accordance
with applicable guidelines to be issued
by the Commission.
OMNIBUS RULES IMPLEMENTING THE LABOR
CODE, BOOK III, RULE VII, SECS. 7, 9 AND 15
SECTION 15. Exemptions

2) New business enterprises that may be

established outside the National Capital Region
and export processing zones from July 1, 1989 to
June 30, 1993, whose operation or investments
need initial assistance may be exempted for not
more than three years from the start of
operations, subject to guidelines to be issued by
the Secretary in consultation with the Department
of Trade and Industry and the Department of
Agriculture.
OMNIBUS RULES IMPLEMENTING THE LABOR
CODE, BOOK III, RULE VII, SECS. 7, 9 AND 15
SECTION 15. Exemptions

New business enterprises in Region III

(Central Luzon) and Region IV (Southern
Tagalog) may be exempted for two years
only from start of operations, except those
that may be established in the provinces
of Palawan, Oriental Mindoro, Occidental
Mindoro, Marinduque, Romblon, Quezon
and Aurora, which may also be exempted
for not more than three years from the
start of operations.
OMNIBUS RULES IMPLEMENTING THE LABOR
CODE, BOOK III, RULE VII, SECS. 7, 9 AND 15
SECTION 15. Exemptions

b) Whenever an application for

exemption has been duly filed with the
appropriate office in the
Department/Board, action by the
Regional Office of the Department on
any complaints for alleged non-
compliance with the Act shall be
deferred pending resolution of the
applicant for exemption.
OMNIBUS RULES IMPLEMENTING THE LABOR
CODE, BOOK III, RULE VII, SECS. 7, 9 AND 15
SECTION 15. Exemptions

c) In the event that the application for

exemption is not granted, the workers
and employees shall receive the
appropriate compensation due them as
provided for under the Act plus interest
of one percent per month retroactive to
July 1, 1989 or the start of operations
whichever is applicable.
C. LEAVES
1. Service Incentive Leave

a. Every employee who has

rendered at least 1 year of
service shall be entitled to a
yearly service incentive leave of 5
days with pay.
C. LEAVES
1. Service Incentive Leave
b. This provision shall not apply to those who are already enjoying the benefit
herein provided, those enjoying vacation leave with pay of at least 5 days
and those employed in establishments regularly employing less than 10
employees or in establishments exempted from granting this benefit by the
Secretary of Labor and Employment after considering the viability or
financial condition of such establishment.
c. The grant of benefit in excess of that provided herein shall not be made a
subject of arbitration or any court or administrative action.
 C. LEAVES - OMNIBUS RULES IMPLEMENTING THE
LABOR CODE, BOOK III, RULE V, SECS. 1-6
SECTION 1. Coverage. — This rule
shall apply to all employees except:

(a) Those of the government and any of

its political subdivisions, including
government-owned and controlled
corporations;
(b) Domestic helpers and persons in the
personal service of another;
(c) Managerial employees as defined in
Book Three of this Code;
 C. LEAVES - OMNIBUS RULES IMPLEMENTING THE
LABOR CODE, BOOK III, RULE V, SECS. 1-6
SECTION 1. Coverage. — This rule shall apply to all
employees except:
(d) Field personnel and other employees whose performance
is unsupervised by the employer including those who are
engaged on task or contract basis, purely commission basis,
or those who are paid a fixed amount for performing work
irrespective of the time consumed in the performance thereof;
(e) Those who are already enjoying the benefit herein
provided;
(f) Those enjoying vacation leave with pay of at least five
days; and
(g) Those employed in establishments regularly employing
less than ten employees.
 C. LEAVES - OMNIBUS RULES IMPLEMENTING THE
LABOR CODE, BOOK III, RULE V, SECS. 1-6
SECTION 2. Right to service incentive leave. — Every
employee who has rendered at least one year of
service shall be entitled to a yearly service incentive
leave of five days with pay.

SECTION 3. Definition of certain terms. — The term “at

least one-year service” shall mean service for not less
than 12 months, whether continuous or broken
reckoned from the date the employee started working,
including authorized absences and paid regular
holidays unless the working days in the establishment
as a matter of practice or policy, or that provided in
the employment contract is less than 12 months, in
which case said period shall be considered as one year.
 C. LEAVES - OMNIBUS RULES IMPLEMENTING THE
LABOR CODE, BOOK III, RULE V, SECS. 1-6
SECTION 4. Accrual of benefit. — Entitlement to the benefit
provided in this Rule shall start December 16, 1975, the date
the amendatory provision of the Code took effect.

SECTION 5. Treatment of benefit. — The service incentive

leave shall be commutable to its money equivalent if not used
or exhausted at the end of the year.

SECTION 6. Relation to agreements. — Nothing in the Rule

shall justify an employer from withdrawing or reducing any
benefits, supplements or payments as provided in existing
individual or collective agreements or employer’s practices or
policies.
C. LEAVES
2. Leaves under Special Laws

A solo parent is now entitled to a

forfeitable and cumulative parental
leave of not more than seven (7) days
as long as they have worked for at
least six (6) months, as compared to
the old law wherein they must render
one (1) year of service.
 C. LEAVES
2. Leaves under Special Laws
Gynecological Leave – R.A. No. 9710
A woman employee having rendered
continuous aggregate employment
service of at least 6 months for the last
12 months shall be entitled to a special
leave benefit of 2 months with full pay
based on her gross monthly
compensation following surgery
caused by gynecological disorders.
(Section 18, Republic Act No. 9710,
Magna Carta of Women)
C. LEAVES
2. Leaves under Special Laws
Battered Woman Leave – R.A. No. 9262
Victims under this Act shall be entitled to take a paid leave of absence up
to 10 days in addition to other paid leaves under the Labor Code and Civil
Service Rules and Regulations, extendible when the necessity arises as
specified in the protection order.

Any employer who shall prejudice the right of the person under this
section shall be penalized in accordance with the provisions of the Labor
Code and Civil Service Rules and Regulations. Likewise, an employer
who shall prejudice any person for assisting a co- employee who is a
victim under this Act shall likewise be liable for discrimination. (Section 43,
Republic Act No. 9262, Anti-Violence Against Women and Their Children
Act
D. SPECIAL GROUPS OF EMPLOYEES
Art. 130. Facilities for women. The Secretary of Labor and Employment
shall establish standards that will ensure the safety and health of women
employees. In appropriate cases, he shall, by regulations, require any
employer to:

a. Provide seats proper for women and permit them to use such seats when
they are free from work and during working hours, provided they can
perform their duties in this position without detriment to efficiency;
b. To establish separate toilet rooms and lavatories for men and women and
provide at least a dressing room for women;
c. To establish a nursery in a workplace for the benefit of the women
employees therein; and
d. To determine appropriate minimum age and other standards for retirement
or termination in special occupations such as those of flight attendants
and the like.
D. SPECIAL GROUPS OF EMPLOYEES

Art. 132. Family planning services;

incentives for family planning.
a. Establishments which are required by law to
maintain a clinic or infirmary shall provide
free family planning services to their
employees which shall include, but not be
limited to, the application or use of
contraceptive pills and intrauterine devices.
b. In coordination with other agencies of the
government engaged in the promotion of
family planning, the Department of Labor
and Employment shall develop and
prescribe incentive bonus schemes to
encourage family planning among female
workers in any establishment or enterprise.
D. SPECIAL GROUPS OF EMPLOYEES
Maternity leave benefits
HRET v. Panga - Vega
G.R. No. 228236. 2021 LOPEZ, M., J.

Section 18 of RA No. 9710 entitles a woman, who has rendered a continuous

aggregate employment service of at least six months for the last 12 months, a
special leave of two months with full pay based on her gross monthly compensation
following surgery caused by gynecological disorders. In relation to this provision,
the case involving Panga-Vega gives rise to the issue of whether the rules on
maternity leave under Sec. 14, Rule XVI of the Omnibus Rules Implementing Book
V of Executive Order No. 292, which provides that the commuted money value of
the unexpired portion of the special leave need not be refunded, and that when the
employee returns to work before the expiration of her special leave, she may
receive both the benefits granted under the maternity leave law and the salary for
actual services rendered effective the day she reports for work, may have a
suppletory application.
D. SPECIAL GROUPS OF EMPLOYEES
Maternity leave benefits
HRET v. Panga - Vega
G.R. No. 228236. 2021 LOPEZ, M., J.
The Court finds it just and more in accord with the spirit and intent of RA No. 9710
to suppletorily apply the rule on maternity leave to the special leave benefit. Similar
to the special leave benefit under RA No. 9710, a maternity leave under the
Omnibus Rules on Leave seeks to protect the health and welfare of women,
specifically of working mothers, as its primary purpose is to afford them some
measures of financial aid, and to grant them a period of rest and recuperation in
connection with their pregnancies. The special leave benefit should be liberally
interpreted to support the female employee so as to give her further means to afford
her needs, may it be gynecological, physical, or psychological, for a holistic
recuperation. The recovery period may be a trying time that she needs much
assistance and compassion to regain her overall wellness. Nothing in RA No. 9710
and the CSC Guidelines bar this more humane interpretation of the provision on
special leave benefit.
D. SPECIAL GROUPS OF EMPLOYEES
Maternity leave benefits
HRET v. Panga - Vega
G.R. No. 228236. 2021 LOPEZ, M., J.

Based on these facts on record, the CSC found that Panga-Vega sufficiently
complied with the CSC Guidelines warranting her return to work. The Court accords
finality to these findings acknowledging the CSC's special knowledge and expertise
on matters falling under its jurisdiction as an administrative agency, and given the
affirmance by the CA.

FOR THESE REASONS, the petition is DENIED. The Decision dated April 29, 2016
and Resolution dated November 8, 2016 of the Court of Appeals in CA-G.R SP No.
128947 are AFFIRMED.
D. SPECIAL GROUPS OF EMPLOYEES
Art. 133. Discrimination prohibited.
It shall be unlawful for any employer to
discriminate against any woman employee
with respect to terms and conditions of
employment solely on account of her sex.
The following are acts of discrimination:
a. Payment of a lesser compensation,
including wage, salary or other form of
remuneration and fringe benefits, to a
female employees as against a male
employee, for work of equal value; and
b. Favoring a male employee over a female
employee with respect to promotion,
training opportunities, study and
scholarship grants solely on account of
their sexes.
D. SPECIAL GROUPS OF EMPLOYEES
Art. 133. Discrimination prohibited.

Criminal liability for the willful commission of

any unlawful act as provided in this Article or
any violation of the rules and regulations
issued pursuant to Section 2 hereof shall be
penalized as provided in Articles 288 and 289
of this Code: Provided, That the institution of
any criminal action under this provision shall
not bar the aggrieved employee from filing an
entirely separate and distinct action for money
claims, which may include claims for damages
and other affirmative reliefs. The actions
hereby authorized shall proceed independently
of each other.
D. SPECIAL GROUPS OF EMPLOYEES
Art. 134. Stipulation against
marriage.
It shall be unlawful for an employer to
require as a condition of employment or
continuation of employment that a
woman employee shall not get married,
or to stipulate expressly or tacitly that
upon getting married, a woman
employee shall be deemed resigned or
separated, or to actually dismiss,
discharge, discriminate or otherwise
prejudice a woman employee merely by
reason of her marriage. – Exception
D. SPECIAL GROUPS OF EMPLOYEES
ART. 135. Prohibited Acts. It shall be
unlawful for any employer:
(1) To deny any woman employee the
benefits provided for in this Chapter or to
discharge any woman employed by him
for the purpose of preventing her from
enjoying any of the benefits provided
under this Code;
(2) To discharge such woman on account of
her pregnancy, or while on leave or in
confinement due to her pregnancy;
(3) To discharge or refuse the admission of
such woman upon returning to her work
for fear that she may again be pregnant.
D. SPECIAL GROUPS OF EMPLOYEES
ART. 136. Classification of Certain Women
Workers.

Any woman who is permitted or suffered to work,

with or without compensation, in any night club,
cocktail lounge, massage clinic, bar or similar
establishments under the effective control or
supervision of the employer for a substantial period
of time as determined by the Secretary of Labor and
Employment, shall be considered as an employee
of such establishment for purposes of labor and
social legislation.
D. SPECIAL GROUPS OF EMPLOYEES
Minors – R.A. No. 7610, as amended by R.A. No. 9231
D. SPECIAL GROUPS OF EMPLOYEES
Kasambahay – R.A. No. 10361
a. Rights and privileges
i. Standard of treatment
ii. Board, lodging and medical attendance
iii. Guarantee of privacy
iv. Access to outside communication
v. Right to education and training
vi. Prohibition against privileged information
b. Terms and conditions of employment
i. Health and safety
ii. Daily rest period
iii. Weekly rest period – day-off
iv. Assignment to non-household work
v. Extent of duty
vi. Minimum wage
vii. Payment of wages
viii. Pay slip
ix. Prohibition on interference in the disposal of wages
x. Prohibition against withholding of wages
D. SPECIAL GROUPS OF EMPLOYEES
Homeworkers – Labor Code, Arts. 151-153
Art. 151. Regulation of industrial homeworkers. The
employment of industrial homeworkers and field personnel
shall be regulated by the government through the
appropriate regulations issued by the Secretary of Labor
and Employment to ensure the general welfare and
protection of homeworkers and field personnel and the
industries employing them.

Art. 152. Regulations of Secretary of Labor. The

regulations or orders to be issued pursuant to this Chapter
shall be designed to assure the minimum terms and
conditions of employment applicable to the industrial
homeworkers or field personnel involved.
D. SPECIAL GROUPS OF EMPLOYEES
Homeworkers – Labor Code, Arts. 151-153
Art. 153. Distribution of homework. For purposes of this Chapter,
the “employer” of homeworkers includes any person, natural or
artificial who, for his account or benefit, or on behalf of any person
residing outside the country, directly or indirectly, or through an
employee, agent contractor, sub-contractor or any other person:
1.Delivers, or causes to be delivered, any goods, articles or materials
to be processed or fabricated in or about a home and thereafter to be
returned or to be disposed of or distributed in accordance with his
directions;
2.Sells any goods, articles or materials to be processed or fabricated
in or about a home and then rebuys them after such processing or
fabrication, either by himself or through some other person.
D. SPECIAL GROUPS OF EMPLOYEES
Night Workers – Labor Code, arts. 154-161
ART. 154. Coverage. This chapter shall
apply to all persons, who shall be
employed or permitted or suffered to work
at night, except those employed in
agriculture, stock raising, fishing, maritime
transport and inland navigation, during a
period of not less than seven (7)
consecutive hours, including the interval
from and employers. Night worker means
any employed person whose work
requires performance of a substantial
number of hours of night work which
exceeds a specified limit.
D. SPECIAL GROUPS OF EMPLOYEES
Night Workers – Labor Code, arts. 154-161
ART. 155. Health Assessment.
ART. 156. Mandatory Facilities.
ART. 157. Transfer.
ART. 158. Women Night Workers
ART. 159. Compensation.
ART. 160. Social Services.
ART. 161. Night Work Schedules.
Apprentices and Learners – Labor Code, arts. 58-60 and 73-74
Apprentices and Learners – Labor Code, arts. 58-60 and 73-74
When Learners May Be Hired?

YES. Learners may be employed when

no experienced workers are available,
the employment of learners is necessary
to prevent curtailment of employment
opportunities, and the employment does
not create unfair competition in terms of
labor costs or impair or lower working
standards. ART. 74.
D. SPECIAL GROUPS OF EMPLOYEES
7. Persons with Disabilities – R.A. No. 7277, as amended by R.A. No.
9442, R.A. No. 10070 and R.A. No. 10524
RA No. 10524
AN ACT EXPANDING THE POSITIONS RESERVED FOR PERSONS WITH DISABILITY, AMENDING FOR
THE PURPOSE REPUBLIC ACT NO. 7277, AS AMENDED, OTHERWISE KNOWN AS THE MAGNA CARTA
FOR PERSONS WITH DISABILITY
 E. Sexual Harassment in the Work Environment (R.A.
No. 7877);
Philipine Airlines Inc., v. Yañez
G.R. No. 214662. 2022 LOPEZ, M., J.
Preliminarily, sexual harassment under Section 3 of RA No. 7877 may
give rise to civil, criminal, and administrative liability, and an action for
each can proceed independently of the others. Moreover, Section 6
authorizes the institution of an independent civil action for damages
and other affirmative relief. In Domingo v. Rayala, we emphasized
that the employee's liability for an administrative offense of sexual Sarte Yañez
harassment should not be determined solely based on Section 3 of
RA No. 7877. Substantial evidence to support, the administrative
charge is sufficient. Thus, the "demand, request, or requirement of
a sexual favor" requirement in Section 3 is not essential before an
act can be qualified as sexual harassment in an administrative
charge. It is enough that the respondent's actions created an
intimidating, hostile, or offensive environment for the employee.
 E. Sexual Harassment in the Work Environment (R.A.
No. 7877)
Philipine Airlines Inc., v. Yañez
G.R. No. 214662. 2022 LOPEZ, M., J.
Thus, it is not necessary that sexual favors or advances
are made to constitute an act of sexual harassment. It is
enough that Yañez’s inappropriate conduct towards Sarte
and in other instances, created a hostile work
environment and uneasy feeling upon Sarte, which Sarte Yañez
affected her job. It came to a point where Sarte would get
anxious every time she attended a Cebu flight and often
requested other flight attendants to exchange with her
supposed schedule or post just to avoid interacting with
Yañez. Verily, the investigating committee found Sarte's
testimony credible, and the labor tribunals arrived at a
similar conclusion.
E. Safe Spaces Act (R.A. No. 11313, Article IV)
GENDER-BASED SEXUAL HARASSMENT IN THE WORKPLACE
F. Discriminatory Practices

1.Age – R.A. No. 10911

An Act Prohibiting
Discrimination Against Any
Individual in Employment on
Account of Age and Providing
Penalties Therefor
F. Discriminatory Practices

2. Gender and Marital Status – R.A. No. 9710

3. Pregnancy – R.A. No. 10354, sec. 23(c)
4. Illness – DOLE D.A. No. 05-10 (HEPA) ; DOLE D.O. No. 73-
05 (TB)
5. Solo Parents – R.A. No. 8972, as amended by R.A. No.
11861, sec. 7
6. Persons with Disability – R.A. No. 7277, as amended
V. SOCIAL WELFARE BENEFITS
A. SSS Law (R.A. No. 8282, as amended by R.A. No. 11199)
Compulsory Coverage:
▪ Employer (Business or Household Employer)
▪ Employee
▪ Self-Employed
▪ Househelper or Kasambahay
▪ Overseas Filipino Workers (OFW) (land-
based and sea-based, except for Filipino
permanent migrants, including Filipino
immigrants, permanent residents, and
naturalized citizens of their host countries,
who may be covered on a voluntary basis)
Voluntary Coverage:
▪ Non-Working Spouse (NWS)
▪ Separated Members
A. SSS Law (R.A. No. 8282, as amended by R.A. No. 11199)
A. SSS Law (R.A. No. 8282, as amended by R.A. No. 11199)
V. SOCIAL WELFARE BENEFITS
B. GSIS Law (R.A. No. 8291)
Compulsory Coverage:
▪ all employees receiving compensation who have not
reached the compulsory retirement age, irrespective of
employment status
EXCEPTION:
❑Members of the Judiciary and Constitutional Commissions who are covered by
separate retirement laws;
❑Contractual employees who have no employee-employer relationship with their
agencies;
❑Uniformed members of the AFP and the PNP, including the BJMP and the BFP.
BENEFITS AND SERVICES
The principal benefit package of the GSIS consists of compulsory and optional life
insurance, retirement, separation, and Employee’s Compensation (EC) benefits.
V. SOCIAL WELFARE BENEFITS
C. Limited Portability Law (R.A. No. 7699)
Totalization
It refers to the process of adding up the periods of
creditable services or contributions under each of
the Systems, SSS or GSIS, for the purpose of
eligibility and computation of benefits.
Hence, if a worker is not entitled to any benefits
under SSS or GSIS because the periods of his
creditable services or contributions does not
qualify to avail any benefit under SSS or GSIS, as
the case may be, he/she could apply
the totalization rule. Applying the totalization rule
can increase the chances of a worker to avail of
benefits under the subject law.
Applicable when one cannot avail any benefits from GSIS or SSS, as the case may be, since
the subject law intends that the employee may be able to get some benefits for his/her years
of work. This is in conformity with the objective of the Portability Law which is to ensure the
social welfare of employees in any sector.
Maryville Manila Inc., v. Espinosa
G.R. No. 229372 2020 LOPEZ, M., J.
At any rate, there is no substantial evidence on the link
between Lloyd's supposed illnesses and nature of
work. Foremost, piracy is a risk confronting all
seafarers while in voyage, but the clinical report only
made general statements on punishments and
deprivation of food, water and liberty. The relationship
of the risk and the diseases was not fairly established.
There was no proof or explanation as to how Lloyd
acquired the illnesses as a result of the hostage
incident. The psychologists hastily concluded that
Lloyd's conditions started after the piracy. Moreover,
Lloyd's actions after the hostage incident are
incompatible with the clinical psychologist's findings.
Lloyd was repatriated from M/V Renuar on May 5,
2011 but he applied again and was deployed on
January, 10, 2012 on board M/V Iron Manolis.
Maryville Manila Inc., v. Espinosa
G.R. No. 229372 2020 LOPEZ, M., J.
There is no indication, during the intervening period of
eight months from repatriation to deployment, that Lloyd
experienced any sign of the alleged diseases. In fact,
Lloyd passed the pre-employment medical examination
and was cleared for re-employment. Lloyd even claimed
that he "more than fully and ably discharged his duties
and responsibilities expected of him on board the
vessel." Verily, it would be improbable for Lloyd to
properly perform his tasks as he claims if he had
palpitations, chest pains, tremors, muscle tension,
dizziness, upset stomach, fatigue, irritability, restlessness
and total lack of sleep. Quite the contrary, these
symptoms were belied since Lloyd lasted for seven
months in M/V Iron Manolis.
Maryville Manila Inc., v. Espinosa
G.R. No. 229372 2020 LOPEZ, M., J.
All told, Lloyd is not entitled to total and permanent disability benefits
for failure to prove that he was repatriated for medical reasons and
that a reasonable link exists between his illnesses and nature of work.
Absent substantial evidence as reasonable basis, this Court is left
with no choice but to deny Lloyd's claim for disability benefits, lest an
injustice be caused to his employer. The award of compensation and
disability benefits cannot rest on speculations, presumptions and
conjectures. Although labor contracts are impressed with public
interest and the provisions of the POEA-SEC must be construed
logically and liberally in favor of Filipino seamen in the pursuit of their
employment on board ocean-going vessels, still the rule is that justice
is in every case for the deserving, to be dispensed with in the light of
established facts, the applicable law, and existing jurisprudence.
One Shipping Corporation v. Heirs of Abbarientos
G.R. No. 255802 2022 LOPEZ, M., J.

SECTION 30. Prescription of Action. — All claims arising

from this contract shall be made within three (3) years
from the date the cause of action arises, otherwise the
same shall be barred.
The Panel, as affirmed by the CA, ruled that respondents'
cause of action accrued upon petitioner's denial of
respondents' claim on September 3, 2015, not upon
Ricardo's death on September 3, 2014, because "it [was]
at [that point when] petitioner may be said to have
committed a breach of its obligation towards Ricardo and
his heirs." Hence, it was held that the filing of the
complaint on March 2, 2018 was well-within the three-
year prescriptive period.
One Shipping Corporation v. Heirs of Abbarientos
G.R. No. 255802 2022 LOPEZ, M., J.

He failed to prove that he had indeed been exposed to the

chemicals/substances he claimed he was exposed to
during his employment contract; how these
substances/chemicals could have caused his ampullary
cancer; or measures that the company did or did not take
to control the hazards occasioned by the use of such
substances/chemicals, to prevent or to lessen his
exposure to them.