How have courts interpreted statute of limitations provisions in the California Labor Code?

We recognize that "statute of limitations provisions in the Labor Code must be liberally construed in favor of the injured employee and ... such enactments should not be interpreted in a manner which results in loss of compensation unless otherwise compelled by specific statutory language." (Newton v. Workers'

[5 Cal.Rptr.3d 835]

Comp. Appeals Bd., supra, 17 Cal.App.4th at p. 154, 21 Cal.Rptr.2d 146.) However, the rule of liberal construction "should not be used to defeat the overall statutory framework and fundamental rules of statutory construction." (Nickelsberg v. Workers' Comp. Appeals Bd. (1991) 54 Cal.3d 288, 298, 285 Cal.Rptr. 86, 814 P.2d 1328.)