GR L 55539; (October, 1983) (Digest)
G.R. No. L-55539 October 27, 1983
DIOSA DE LEON, petitioner, vs. EMPLOYEES’ COMPENSATION COMMISSION and REPUBLIC OF THE PHILIPPINES, GOVERNMENT SERVICE INSURANCE SYSTEM, MINISTRY OF NATIONAL DEFENSE (PHILIPPINE NAVY), respondents.
FACTS
This case originated from a claim for death benefits filed by petitioner Diosa de Leon under the Employees’ Compensation Act. The claim was based on the death of her husband, who was an employee of the Philippine Navy under the Ministry of National Defense. The Government Service Insurance System (GSIS) and the Employees’ Compensation Commission (ECC) denied the claim, leading to this petition for review before the Supreme Court.
In its initial decision dated November 19, 1982, the Supreme Court granted the petition and set aside the ECC’s decision. It ordered the respondents to pay the claimed benefits. Subsequently, the respondent GSIS filed a motion for reconsideration and clarification, specifically regarding which entity—the GSIS or the employer—should be liable for the payment of the compensation benefits awarded to the petitioner.
ISSUE
The primary issue for resolution in this motion is the determination of the proper party liable for the payment of employees’ compensation benefits for claims that accrued prior to the effectivity of the present Labor Code.
RULING
The Supreme Court granted the motion for reconsideration filed by the GSIS. It amended the dispositive portion of its November 19, 1982 decision. The Court clarified that for claims which accrued prior to the present Labor Code, the employer, not the GSIS, is the liable party for payment. This ruling is consistent with a line of established jurisprudence, including the cases of Avendaño vs. ECC, Lao vs. ECC, Corales vs. ECC, Villones vs. ECC, Cañeja vs. ECC, Barga, Jr. vs. ECC, Panangui vs. ECC, and Segismundo vs. ECC.
Consequently, the Court ordered the Ministry of National Defense (Philippine Navy), as the employer, to pay the petitioner the death benefits amounting to Six Thousand Pesos (P6,000.00), to refund duly receipted medical and hospital expenses, to pay burial expenses of Two Hundred Pesos (P200.00), and to pay attorney’s fees of Six Hundred Pesos (P600.00). The legal logic rests on the principle that under the applicable law for pre-Labor Code claims, the compensation system was employer-liability based, making the employing agency directly responsible for satisfying such awards, as distinguished from the state insurance scheme established under the later Code.