Wack Wack Golf & Country Club v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Antonio G. Valentin was employed by Wack Wack Golf and Country Club, Inc. as a cook from 1935 to December 1941, and re-employed from May 1947 until April 15, 1952. He was diagnosed with tuberculosis and was given a four-month leave with pay starting April 15, 1952. His illness did not improve despite medical treatment provided by the Club, leading to his dismissal in August 1952, with separation pay. Procedural History: Valentin filed a claim for compensation with the Workmen's Compensation Commission in September 1952. The Club contended that the disease was not compensable as it did not arise out of and in the course of employment, and that Valentin was excluded from the Workmen's Compensation Act because his weekly salary exceeded P42, as per Section 39(b) as amended by Commonwealth Act 210. The Petition: The Commission awarded disability benefits, ruling that Valentin's illness was caused or aggravated by his employment and that his separation was due to the illness. The Commission reasoned that Section 39(b) was repealed by Republic Act 7721, which took effect on June 20, 1952, and Valentin was separated after its passage. The Wack Wack Golf and Country Club, Inc. filed a Petition for Certiorari, arguing that Republic Act 772 was not applicable as Valentin contracted the illness prior to April 17, 1952.
Issue(s)
Whether Republic Act 772 governs the claim for compensation. Whether the exclusionary clause in Section 39(b) of Act No. 3428, as amended by Commonwealth Act 210, applies to Antonio G. Valentin's claim. Whether the subsequent repeal of the exclusionary clause by Republic Act 7721 retroactively makes Valentin's claim compensable.
Ruling
The award of the Workmen's Compensation Commission is reversed, and the petitioner is absolved from all liability.
Ratio Decidendi
On whether Republic Act 772 governs the claim for compensation: The Court held that Republic Act 772 does not govern the claim because it has no provision making it applicable to claims whose causes of action accrued prior to its enactment. The injury or event on which the claim rests, which is the contraction or aggravation of tuberculosis, occurred on or before April 17, 1952, when Valentin went on leave due to his illness. He did not work after this date, thus the illness could not have been aggravated by his work after April 17, 1952. The Court emphasized the principle of non-retroactivity of statutes, stating that legislative enactments are deemed prospective unless a contrary intent is clearly expressed. This principle has been applied to workmen's compensation acts, which do not apply to injuries occurring before the law went into effect. On whether the exclusionary clause in Section 39(b) of Act No. 3428, as amended by Commonwealth Act 210, applies to Antonio G. Valentin's claim: The Court found that at the time Valentin became disabled on or before April 17, 1952, employees receiving a weekly compensation of more than P42 were expressly excluded from the benefits of the Workmen's Compensation Act. The facts indicate that Valentin's salary was P200 a month or P46.62 a week, which exceeded the P42 threshold. Therefore, under the law then in effect, he was not entitled to compensation. On whether the subsequent repeal of the exclusionary clause by Republic Act 7721 retroactively makes Valentin's claim compensable: The Court ruled that the elimination of the exclusionary clause from the statutes on June 20, 1952, by Republic Act 7721, could not render compensable an injury or illness that occurred prior to its enactment. The right for compensation is governed by the law in force at the time of the occurrence of the injury. Since Valentin's disability occurred on or before April 17, 1952, the law applicable was the one that excluded employees with weekly salaries exceeding P42. The subsequent repeal of this exclusion did not retroactively apply to his claim. The Court cited Amadeo vs. Olabarrieta (95 Phil., 33) in support of the non-retroactivity of Republic Act 772.
Main Doctrine
The application of a statute, particularly concerning workmen's compensation, is governed by the law in force at the time of the occurrence of the injury or illness, and subsequent amendments or repeals do not have retroactive effect unless expressly stated.