G.R. No. L-32120 December 17, 1975
GERTRUDES I. VDA. DE OLIB, ET AL. vs. CITY OF MANILA, WORKMEN’S COMPENSATION COMMISSION AND REPUBLIC OF THE PHILIPPINES (Department of Education and Culture and Bureau of Public Schools)
FACTS
Petitioners, the widow and minor children of the deceased Nunilon Olib, filed a claim for compensation arising from his death on June 22, 1961. Olib, a janitor-watchman at Mapa High School, died from tetanus resulting from a wound he sustained while discharging his duties at the school building. The claim was initially filed against the City of Manila.
The Workmen’s Compensation Commission set aside the original award issued by Regional Office No. 3 in favor of the petitioners. The Commission found that the claim was filed against the wrong party, as the deceased was an employee of the national government, specifically the Bureau of Public Schools under the Department of Education and Culture, and not an employee of the City of Manila.
ISSUE
Whether the claim for death compensation benefits can be properly enforced against the national government despite having been initially filed against the wrong party.
RULING
Yes. The Supreme Court upheld the setting aside of the original award against the City of Manila, as it was not the proper employer. However, in the interest of justice and to avoid undue delay, the Court ordered the impleading of the Republic of the Philippines, through the Department of Education and Culture and the Bureau of Public Schools, as the proper respondent.
The Solicitor General, representing the national government, recognized the compensability of the death and expressly offered no objection to the enforcement of the award. The Court emphasized the mandate of the Workmen’s Compensation Act, which requires that proceedings be conducted without regard to technicalities and legal forms, with the objective of promoting substantial justice and equity. Substantial evidence supported the finding that the death arose from and in the course of employment.
Accordingly, the Court adjudged the Republic of the Philippines, specifically the Department of Education and Culture, as the employer, liable to pay the awarded death compensation benefits, burial expenses, attorney’s fees, and administrative fees. The national government was enjoined to satisfy the award forthwith.
