G.R. No. L-42134 April 30, 1976
ABOITIZ & COMPANY, INC., petitioner, vs. WORKMEN’S COMPENSATION COMMISSION, HERMOGENA T. CAÑETE and PIONEER DETECTIVE CREDIT SECURITY AGENCY, INC., respondents.

FACTS

Anastacio Cañete, a security guard employed by Pioneer Detective Credit Security Agency, Inc., was assigned to guard the premises of Aboitiz & Company, Inc. He died from hypertensive heart disease which caused a fatal heart attack in the course of his employment. His widow, Hermogena T. Cañete, filed a claim for death benefits under the Workmen’s Compensation Act. The Workmen’s Compensation Commission affirmed its unit’s decision, holding petitioner Aboitiz & Company liable as the statutory employer and ordering it to pay death benefits, burial expenses, and attorney’s fees.
Aboitiz sought a review, specifically contesting the commission’s failure to hold respondent Pioneer Detective Credit Security Agency, Inc., liable for reimbursement. The Supreme Court denied the petition for review of the commission’s decision against Aboitiz but gave limited due course to the petition regarding Aboitiz’s claim for reimbursement from the security agency. The Court treated this limited aspect as a special civil action.

ISSUE

Whether respondent Pioneer Detective Credit Security Agency, Inc., as the direct employer, can be held liable to reimburse petitioner Aboitiz & Company, Inc., for the death compensation benefits awarded against Aboitiz as the statutory employer.

RULING

Yes. The Supreme Court ruled that while petitioner Aboitiz was correctly held statutorily liable as the owner of the establishment where the guard was assigned, respondent security agency must be held ultimately liable as the direct employer. The legal logic is twofold. First, under the Workmen’s Compensation Act, the definition of “employer” includes the owner or lessee of an establishment where work is carried on, making such entity statutorily liable to ensure compensation is paid to the worker, even if they are not the direct employer. This statutory liability is imposed to protect the worker.
Second, and decisively for the reimbursement claim, the security agency was the direct employer who employed, paid, and furnished the guard in the regular course of its business. Furthermore, the contract for security services between Aboitiz and Pioneer expressly stipulated that the agency “shall solely assume all responsibilities and liabilities for any claim… under the Workmen’s Compensation Act.” This express contractual undertaking created an obligation for the agency to hold Aboitiz harmless from such claims. Therefore, as the direct employer bound by contract, the security agency is ultimately responsible. The Court rendered judgment sentencing Pioneer Detective Credit Security Agency, Inc., to reimburse petitioner Aboitiz for all amounts adjudged against it by the commission.