GR L 9641; (May, 1957) (Digest)
G.R. No. L-9641; May 24, 1957
WACK WACK GOLF & COUNTRY CLUB, INC., petitioner, vs. WORKMEN’S COMPENSATION COMMISSION and ANTONIO VALENTIN, respondents.
FACTS
Antonio G. Valentin was employed as a chief cook by the Wack Wack Golf and Country Club, Inc. from 1935 to December 1941, and was re-employed from May 1947 until April 15, 1952. On April 17, 1952, due to illness (tuberculosis), he was placed on a four-month leave with pay. At the end of his leave in August 1952, his ailment had not improved, and he was dismissed, receiving separation pay equivalent to two months’ salary. In September 1952, he filed a claim for disability benefits with the Workmen’s Compensation Commission. The Club contested the claim, arguing that the illness did not arise from employment and that the Workmen’s Compensation Act (Act No. 3428 as amended by Commonwealth Act 210) excluded employees whose weekly remuneration, exclusive of overtime, exceeded P42, which Valentin earned (P46.62 per week). The Commission awarded benefits, holding that Republic Act No. 772, which took effect on June 20, 1952, and removed the salary exclusion, applied because Valentin was separated in August 1952, after the law’s approval.
ISSUE
Whether Republic Act No. 772, which removed the salary exclusion for compensation benefits, applies retroactively to Valentin’s claim, or whether Act No. 3428 as amended (with the P42 weekly salary exclusion) governs, given that his illness and disability occurred before the new law’s effectivity.
RULING
The Supreme Court reversed the Commission’s award and absolved the petitioner from liability. The Court held that the law in force at the time of the injury or event giving rise to the claim governs compensation. Valentin’s illness (tuberculosis) was contracted or aggravated on or before April 17, 1952, when he went on leave, and he did not work thereafter. At that time, Act No. 3428 as amended, which excluded employees earning over P42 per week, was applicable. Republic Act No. 772, which removed this exclusion, took effect on June 20, 1952, and contains no provision for retroactive application. Following the established principle that laws are prospective unless clearly intended otherwise, and that compensation rights are determined by the law at the time of injury, Valentin’s claim was not compensable due to the salary exclusion in effect when his disability arose. The Court noted the Club had provided significant assistance, including medical expenses and separation pay.