G.R. No. L-19325; February 28, 1964
ISABEL Q. JUECO, petitioner, vs. FELICIDAD FLORES, respondent.

FACTS

Respondent Felicidad Flores filed a claim under the Workmen’s Compensation Act for the death of her son, Emiliano Flores, alleging he was employed as a truck helper by petitioner Isabel Q. Jueco and died on April 25, 1957, after being pinned between two trucks owned by Jueco while performing his duties. Jueco contested the claim, denying any employer-employee relationship with the deceased. She asserted that Emiliano was never her employee and presented a payroll for April 1957 that did not include his name. Jueco also claimed she had settled the matter through a separate release document and a P400.00 payment made under her alleged subsidiary liability as the employer of the truck driver who caused the accident, not as the employer of the deceased.
The Hearing Officer found an employer-employee relationship existed and awarded death benefits. The Workmen’s Compensation Commission affirmed this finding but modified the compensation amount. Jueco appealed to the Supreme Court, assigning errors primarily on the lack of substantial evidence for the employer-employee relationship and the dependency finding, the failure to deduct the P400.00 payment from the award, and the allegedly baseless award of attorney’s fees.

ISSUE

The core issues were: (1) whether substantial evidence supported the finding of an employer-employee relationship between Jueco and the deceased; (2) whether the P400.00 payment should be deducted from the compensation award; and (3) whether the award of attorney’s fees against the employer was legal.

RULING

The Supreme Court affirmed the Commission’s decision with modification. On the first issue, the Court held that substantial evidence, not preponderance of evidence, is the standard in workmen’s compensation cases. The Commission correctly relied on sworn statements given by co-workers to police on the day of the accident, which referred to Emiliano as their “co-worker.” The immediacy of these statements, made before any compensation claim was contemplated, lent them credibility and sufficiently established the employment relationship, outweighing Jueco’s later-presented payroll and the recanting testimony of a witness.
On the second issue, the Court found merit in Jueco’s claim for deduction. Although she initially characterized the P400.00 payment as stemming from a different, subsidiary liability, the Court ruled that, since she was ultimately adjudged liable as the employer under the Workmen’s Compensation Act, fairness and justice required that the amount be considered an advance payment on the compensation due. Consequently, the P400.00 was ordered deducted from the awarded sum of P1,996.80.
Regarding attorney’s fees, the Court upheld the award against the employer. It interpreted Sections 7, 29, and 47 of the Workmen’s Compensation Act collectively, concluding that the Commission has the power to fix attorney’s fees and to designate the liable party. To require the claimant to pay the fees would diminish the compensation intended by law to be kept intact for the beneficiary. Since the law imposes liability on the employer for medical expenses, it stands to reason the employer should also bear the cost of attorney’s fees in such cases. The decision was thus affirmed as modified.