Doce v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Dado Jadao, a conductor for Bus No. 9 owned by Isabelo Doce, operated under a boundary system. Jadao's average daily earnings were P4.00, working five days a week. Under the boundary system, the driver and conductor paid Doce a fixed amount of P15.00 daily. The owner initially supplied gasoline, the cost of which was reimbursed from daily earnings. The remainder of the earnings, after deducting gasoline costs and the P15.00 rental, was divided between the driver and conductor. On June 11, 1953, Jadao suffered injuries to his right leg, head, and left ear when pinned by two buses on Quezon Boulevard, Manila, while acting as conductor. He experienced temporary total disability from June 11, 1953, to May 10, 1954, and a partial loss of the use of his right leg. Procedural History: Jadao filed a claim for compensation with the Workmen's Compensation Commission. Doce raised the defense of lack of employer-employee relationship, questioning the Commission's jurisdiction. A referee ruled that a conductor under the boundary system is an employee and ordered Doce to pay Jadao P757.43 in compensation, plus medical and surgical expenses, and P8.00 in fees to the Commission. The Commission affirmed this decision. The Petition: Doce filed a petition for review, challenging the existence of the employer-employee relationship and the Commission's jurisdiction.
Issue(s)
Whether an employer-employee relationship exists between a bus owner and a conductor working under a boundary system for purposes of the Workmen's Compensation Act.
Ruling
The decision of the Workmen's Compensation Commission is affirmed. The employer-employee relationship is deemed to exist between the bus owner and the conductor operating under the boundary system.
Ratio Decidendi
On Issue 1: The Supreme Court held that an employer-employee relationship is present despite the use of the boundary system. Applying the doctrine in National Labor Union vs. Dinglasan, the Court clarified that the features making the relationship look like a lease—such as the lack of a fixed wage and the worker bearing the cost of gasoline—are insufficient to withdraw the relationship from the ambit of employment. The Court reasoned that Jadao and the driver had no interest in the business because they did not invest in the acquisition of the vehicles nor did they participate in the management of the operations. Since their only contribution was their labor, they cannot be considered lessees of the vehicle. Furthermore, the Court noted that the boundary system is merely a method of calculating compensation where the driver's earnings are the excess of fares over the boundary amount. Consequently, as an employee, Jadao is entitled to the benefits provided under the Workmen's Compensation Act, and the Commission properly exercised jurisdiction over the dispute.
Main Doctrine
A conductor working under a boundary system for a bus owner is considered an employee within the meaning of the Workmen's Compensation Act, establishing an employer-employee relationship that grants the Workmen's Compensation Commission jurisdiction over claims for compensation.