GR L 47414; (May, 1988) (Digest)
G.R. No. L-47414. May 23, 1988.
ELIODORO T. ISCALA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Department of Education & Culture, Bureau of Public Schools), GOVERNMENT SERVICE INSURANCE SYSTEM, and the EMPLOYEES’ COMPENSATION COMMISSION, respondents.
FACTS
The petitioner, Eliodoro T. Iscala, filed a claim for death compensation benefits following the demise of his wife, Nena S. Iscala, who was employed as a public school teacher. The claim was initially denied by the Employees’ Compensation Commission (ECC) in a decision dated October 12, 1977. Iscala elevated the matter to the Supreme Court.
In a decision promulgated on December 11, 1987, the Supreme Court set aside the ECC’s denial. The Court ordered the Government Service Insurance System (GSIS) to award compensation to the petitioner under the provisions of the old Workmen’s Compensation Act. Following this decision, the GSIS filed a Motion for Partial Reconsideration.
ISSUE
The sole issue presented by the Motion for Partial Reconsideration is whether the GSIS, having been ordered to pay compensation benefits under the Workmen’s Compensation Act, possesses a right to seek reimbursement from the employer of the deceased.
RULING
The Supreme Court granted the Motion for Partial Reconsideration and modified its December 11, 1987 decision. The Court anchored its ruling on the established doctrine that when the GSIS is compelled to pay compensation benefits under the old Workmen’s Compensation Act, it is entitled to reimbursement from the employer concerned.
This legal principle was definitively laid down in Corales vs. Employees’ Compensation Commission and has been consistently reiterated in subsequent jurisprudence, including the recent case of Reyes vs. ECC. The logic is rooted in the nature of the employer’s liability; the primary responsibility for work-connected death or injury rests with the employer. The GSIS, as the administering agency, effects the payment but does not assume the employer’s fundamental financial obligation.
Consequently, the Court modified its dispositive portion. The GSIS is ordered to award the due compensation to petitioner Eliodoro T. Iscala. However, this payment is expressly made “without prejudice to its right of reimbursement from the Department of Education, Culture & Sports,” the employer of the deceased teacher. The grant of benefits to the petitioner is thus affirmed, but the ultimate financial burden is correctly placed upon the employing government department.