GR L 34352; (May, 1972) (Digest)
G.R. No. L-34352 May 31, 1972
REPUBLIC OF THE PHILIPPINES (Philippine Constabulary), petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and FLORA A. VDA. DE ANCHEZ, et al., respondents.
FACTS
Corporal Marcelo Anchez, an enlisted man of the 137th PC Company stationed in Imus, Cavite, died on December 7, 1965, from gunshot wounds sustained inside the camp. An official investigation by his unit concluded that, prior to his death, Cpl. Anchez had “run berserk” in a fit of insanity, shooting and killing two fellow soldiers and wounding another. The report found that his death resulted from responsive shots fired by a sergeant acting in self-defense. It recommended that his family be considered for payment of benefits, noting he must have been attacked by insanity while in the performance of duty. His widow and minor children filed a claim for death benefits under the Workmen’s Compensation Act on February 20, 1967. The respondent Commission awarded them the full compensation of P6,000.00 plus attorney’s fees, refusing to deduct the P3,000.00 death gratuity the family had already received under Republic Act No. 610.
ISSUE
Whether the death gratuity received by the heirs under Republic Act No. 610 should be deducted from the compensation award granted under the Workmen’s Compensation Act.
RULING
Yes, the amount received under Republic Act No. 610 must be deducted. The Court, modifying the Commission’s resolution, held that the two statutes provide benefits for the same contingency—the death of a military member. Republic Act No. 610 is a special law granting a gratuity to armed forces personnel who die in line of duty, while the Workmen’s Compensation Act is a general labor legislation. The Court applied the rule that a special law prevails over a general law. However, it also recognized the principle against double compensation for the same event, as the benefits under both laws are intended for the same purpose of providing death compensation. The legislative intent cannot be construed to allow duplicate recovery, especially considering the government’s financial constraints at the time these laws were enacted. Therefore, to prevent unjust enrichment, the P3,000.00 already paid must be credited against the total compensation award. The Court found the death compensable under the Workmen’s Compensation Act, as it occurred in the course of employment, but ordered the deduction.