G.R. No. L-47099 August 26, 1982
IGNACIO DELOS ANGELES, petitioner, vs. GOVERNMENT SERVICE INSURANCE SYSTEM (PHILIPPINE COCONUT AUTHORITY) and THE EMPLOYEES’ COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Ignacio delos Angeles filed a claim for disability compensation benefits. His cause of action, based on an illness contracted during his employment, accrued under the regime of the former Workmen’s Compensation Act. The claim was processed under the new compensation scheme established by the Labor Code (Presidential Decree No. 626), which provides for reduced benefits compared to the old Act. The Employees’ Compensation Commission (ECC) and the Government Service Insurance System (GSIS) denied the claim under the new Code’s stricter provisions.
In a decision dated November 16, 1979, the Supreme Court granted the petition, applying the doctrine established in Corales vs. ECC. The Court awarded delos Angeles compensation benefits, reimbursement for medical expenses, attorney’s fees, and administrative fees under the more favorable provisions of the Workmen’s Compensation Act. Both the ECC and GSIS filed motions for reconsideration. The ECC’s motion was denied. GSIS, however, persisted with its motion, raising several grounds including prescription, the proper source of payment, and its right to reimbursement from the employer.

ISSUE

Whether the petitioner’s claim should be governed by the Workmen’s Compensation Act or the new Labor Code, and consequently, whether the GSIS can seek reimbursement from the employer for benefits paid under the old Act.

RULING

The Supreme Court denied the GSIS motion for reconsideration and affirmed its prior ruling with modification regarding liability. The Court held that the petitioner acquired a vested right to benefits under the Workmen’s Compensation Act, as his cause of action accrued during its effectivity. Following the landmark Corales doctrine, claims with causes of action accruing under the old Act must be resolved under its more favorable provisions, notwithstanding their filing under the new Code. This application upholds the constitutional mandate of social justice, remedying the retrogressive effect of the new compensation scheme.
On the issue of reimbursement, the Court sustained the GSIS’s position. While the GSIS, as the administrator of the State Insurance Fund, was ordered to pay the award directly to the petitioner, it retains the right to seek reimbursement from the actual employer liable under the old Workmen’s Compensation Act—here, the Philippine Coconut Authority. This reimbursement must be pursued after affording the employer due process and a hearing to present any defenses. The award of attorney’s fees to the petitioner was upheld as proper under the old Act. However, the Court deleted the administrative fees from the award against GSIS.