Manila Railroad Company v. Tribunal Industrial
REITERATIONFacts
The Antecedents: Alfonso Sanchez died while in the employ of the Manila Railroad Company. The company had a policy since 1936 where laborers and employees enjoyed 20 days vacation and sick leave, later increased to 30 days and made cumulative. Any unused portion was carried over, and upon resignation or extended sickness, the laborer was entitled to the money equivalent of unused leave not exceeding five months, unless separated for cause, in which case it was forfeited. Procedural History: The Industrial Court ordered the respondent (Manila Railroad Company) to pay the heirs of Alfonso Sanchez the sum of P1,202.67, equivalent to five months and fourteen days of his unused leave. The Petition: The Manila Railroad Company appealed the order of the Industrial Court via certiorari, arguing that if the leave value were paid to the heirs, the company would lose the opportunity to recover it if the employee committed an offense against the company, which would not be fair.
Issue(s)
Whether the heirs of an employee who dies in the performance of his duties are entitled to the monetary equivalent of the employee's accumulated unused leave credits.
Ruling
The order of the Industrial Court is affirmed with costs against the petitioner. The heirs of Alfonso Sanchez are entitled to the payment of the accumulated unused leave of absence.
Ratio Decidendi
On Issue 1: The Court held that the heirs are entitled to the payment of the accumulated leave. It reasoned that since cumulative leave is convertible to cash upon resignation or separation without cause, there is no justification to deny the same benefit to the heirs of a worker who died in the line of duty. The Court noted that the right to such property is transmitted to the heirs by operation of law upon the death of the father. Furthermore, the Court rejected the company's argument regarding potential future offenses, stating that once the employee is deceased, they can no longer commit faults against the company. The Court emphasized that government-capitalized enterprises must lead by example in fulfilling social legislation, as their primary purpose is service and the welfare of their workers rather than maximizing profit. Finally, the Court observed that the issue had already been resolved in the recent precedent of Manila Railroad Company v. CIR and Kapisanan ng mga Manggagawa sa Manila Railroad (G.R. No. L-4616), making the current appeal a wasteful use of time on a settled question.
Main Doctrine
The heirs of a deceased employee are entitled to the monetary equivalent of his accumulated unused leave of absence, even if the company policy allows forfeiture upon separation for cause, as death in service is not a separation for cause that warrants forfeiture.