GR L 17362; (February, 1963) (Digest)
G.R. Nos. L-17362 and L-17367-69; February 28, 1963
MADRIGAL SHIPPING CO., petitioner, vs. MONICA MELAD, FRANCISCA SICCUAN, JUANA SICCUAN, BARBARA TULIAO, PLACIDA DE LA CRUZ, APARRI PILOTS’ ASSOCIATION AND WORKMEN’S COMPENSATION COMMISSION, respondents.
FACTS
Petitioner Madrigal Shipping Co.’s vessel, S.S. “Cetus,” left Aparri for Manila but returned for rudder repairs. The ship’s agent notified the Aparri Pilots’ Association, and Chief Pilot Primitivo Siccuan and District Pilot Francisco Ricerra arranged with Filoteo Siccuan and Domingo Batta to take them to the ship. The party reached the vessel, but it sank due to heavy waves, resulting in the deaths of all four individuals. Their heirs filed claims for compensation under the Workmen’s Compensation Act.
The Workmen’s Compensation Commission, through Regional Office No. 2, awarded death benefits to the claimants. The Commission affirmed the award, prompting this petition. Madrigal Shipping challenges the Regional Office’s jurisdiction, denies any employer-employee relationship with the deceased, and contests the dependency status of some claimants.
ISSUE
The primary issues are: (1) whether Regional Office No. 2 had jurisdiction over the claims; (2) whether an employer-employee relationship existed between Madrigal Shipping and the deceased for compensation purposes; and (3) whether the claimants were legitimate dependents under the law.
RULING
The Supreme Court affirmed the Commission’s decision. On jurisdiction, the Court held that Reorganization Plan 20-A validly conferred authority on the Department of Labor’s Regional Offices to adjudicate workmen’s compensation claims. This was a permissible reallocation of powers already vested in the Department, not an unconstitutional assumption of judicial power, as established in prior rulings like Miller v. Mardo.
On the employer-employee relationship, the Court applied Section 39 of the Workmen’s Compensation Law, which defines “employer” to include any person using the services of another for his business. The pilotage service, essential for the ship’s safe entry for repairs, was in the usual course of Madrigal’s shipping business. Therefore, Madrigal was deemed the statutory employer of the pilots and their assistants, regardless of the direct contract with the Pilots’ Association or its payment of salaries. The law is to be construed liberally in favor of employees.
Regarding dependency, the Court found the Commission’s factual determination that Primitivo Siccuan’s grandchildren were his dependents to be binding, absent a showing of evidentiary lack. Similarly, the proof of Placida de la Cruz’s marriage to Domingo Batta was deemed satisfactory. The award was thus upheld.