G.R. No. L-39566 February 21, 1980
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, petitioner, vs. LEONORA B. ROSAL, ET AL., and THE WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Godofredo Rosal, a Maintenance Technician II for the Philippine Long Distance Telephone Company (PLDT) for twelve years, died on May 4, 1971. His death was allegedly the result of an intra-cranial tumor, tuberculosis, and cardio-respiratory illness, which developed after he sustained a head injury in a work-related vehicular accident on May 30, 1969. His widow, Leonora B. Rosal, and their minor children filed a claim for death benefits under the Workmen’s Compensation Act. The claim was declared uncontroverted, and the Workmen’s Compensation Commission awarded them P6,000.00 as death compensation plus P200.00 for burial expenses.
PLDT sought to set aside the award, arguing it was denied its day in court and that the cause of death was not compensable. This was denied. PLDT then filed a Motion for Reconsideration, contending that the amount of P4,959.96 it had previously paid to the respondents under its company Benefit Plan should be deducted from the compensation award. PLDT relied on a provision in its Plan stating that if an employee is entitled to compensation under the Workmen’s Compensation Law, the heirs shall be entitled to whichever amount is greater between the Workmen’s Compensation award and the Plan benefit.

ISSUE

Whether the amount of P4,959.96 paid by PLDT to the respondents under its company Benefit Plan should be deducted from the death compensation award granted under the Workmen’s Compensation Act.

RULING

The Supreme Court ruled that the amount paid under the company Benefit Plan is not deductible from the statutory compensation award. The legal logic is grounded on the distinct nature and purpose of the two sources of benefits. The Workmen’s Compensation Act is a social legislation designed to provide compensation for work-connected injuries, illness, or death, irrespective of fault, and its benefits are a statutory right. In contrast, the company’s Benefit Plan, as examined in a prior analogous case (PLDT vs. WCC and Marcial Brofas, L-39536), functions as a form of separation, retirement, or gratuity pay. It is available only to permanent and regular employees upon separation, retirement, or death, regardless of whether the cause is work-connected, and is computed based on years of service and salary.
Therefore, the liability of the employer under its private Benefit Plan is separate and distinct from its liability under the public law of the Workmen’s Compensation Act. Payment under the Plan does not extinguish the statutory obligation to pay compensation. The Court affirmed the Commission’s decision, denying the deduction and dismissing PLDT’s petition, as it raised the same issue already settled in the Brofas case. The award of P6,000.00 as death compensation benefits stands.