G.R. No. L-30278 December 14, 1982
JOSE MANAPAT, petitioner, vs. THE HONORABLE WORKMEN’S COMPENSATION COMMISSION and PAULINO SYLIANGCO, doing business under the name of PAVA DEEP SEA FISHING ENTERPRISES, respondents.
FACTS
Petitioner Jose Manapat, a master carpenter, worked for respondent Paulino Syliangco’s PAVA Deep Sea Fishing Enterprises from 1960, performing repair and upkeep on various vessels. On May 27, 1965, while repairing the M/V Don Paulino I, Manapat suffered a cerebro-vascular accident resulting in disability. The Workmen’s Compensation Commission initially awarded him compensation benefits but, upon a motion for reconsideration, reversed itself. The Commission absolved the respondent, ruling that Manapat was an independent contractor and not an employee. It based this on Manapat’s testimony that he hired and paid other carpenters (though with funds from Syliangco and upon his instructions), could dismiss inefficient helpers, and exercised discretion in performing repairs, with his work only being checked upon completion.
ISSUE
Whether petitioner Jose Manapat was an employee or an independent contractor of respondent Paulino Syliangco, thereby entitling him to workmen’s compensation benefits.
RULING
The Supreme Court reversed the Commission and held that Manapat was an employee. The legal logic centered on the application of the four-fold test for an employer-employee relationship, with the power of control being the most determinative element. The Court found that the Commission erred in its interpretation of the facts. Manapat’s discretion in carpentry work and his supervision of other workers were inherent to his role as a master carpenter and foreman, not indicative of independent contractorship. He was a daily wage earner (P10/day), had no independent capital, worked continuously for the respondent from 1960 to 1965 on various tasks including vehicle repairs, and reported to an overall “encargado.” The fact that he hired and disciplined helpers was a delegated supervisory function, and he acted merely as a conduit for wages from Syliangco, the real employer. The informal nature of the relationship in a family business like fishing did not negate the existence of an employment bond. The constitutional and statutory policy of social justice mandated a liberal interpretation in favor of the worker’s coverage. Consequently, Manapat was declared an employee entitled to disability compensation.
