Liwanag v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: Appellants Benito Liwanag and Maria Liwanag Reyes were co-owners of Liwanag Auto Supply. An employee, while in the line of duty, was killed. The widow and minor children of the deceased employee filed a claim for compensation with the Workmen's Compensation Commission. Procedural History: The Workmen's Compensation Commission granted the claim, ordering the appellants to pay jointly and severally the amount of P3,494.40 to the claimants and P4.00 to the Workmen's Compensation Fund. The Petition: Appellants appealed to the Supreme Court, not questioning the right to compensation or the amount, but arguing that the compensation is divisible and that the Commission erred in ordering them to pay jointly and severally, contending that their liability should be merely joint and not solidary in the absence of an express provision in the Workmen's Compensation Act.
Issue(s)
Whether the liability of co-owners of a business for the death of an employee, under the Workmen's Compensation Act, is joint or solidary. Whether the Workmen's Compensation Act, when read in conjunction with the Civil Code, imposes solidary liability on employers.
Ruling
The Supreme Court affirmed the award of the Workmen's Compensation Commission, holding that the liability of the appellants (co-owners/employers) is solidary. The Court ruled that the Workmen's Compensation Act, when interpreted liberally in favor of the employee and in conjunction with Articles 1711 and 1712 of the Civil Code, mandates solidary liability to ensure that the employee's right to compensation is not defeated or crippled, especially in cases where one employer might be insolvent.
Ratio Decidendi
On the issue of whether the liability is joint or solidary: The Court held that while ordinarily the liability of partners is not solidary, this principle does not apply to compensation cases. The Workmen's Compensation Act, together with Articles 1711 and 1712 of the new Civil Code, indicates that the liability of business partners, like the appellants, must be solidary. Article 1711 obliges owners of enterprises to pay compensation for death or injury arising out of employment, even if purely accidental or due to fortuitous cause. Article 1712 further states that if the death or injury is due to the negligence of a fellow-worker, the latter and the employer shall be solidarily liable. Section 2 of the Workmen's Compensation Act provides that the right to compensation shall not be defeated or impaired by the negligence of a fellow servant. The Court reasoned that if the responsibility were merely joint, and one partner were insolvent, the compensation awarded might only be partially satisfied, which is contrary to the Act's intent. The Act should be construed liberally in favor of the employee and their dependents, resolving all doubts in their favor to promote the purpose of the law. On whether the Workmen's Compensation Act imposes solidary liability: The Court found that although the Workmen's Compensation Act does not expressly declare the obligation as solidary, such liability can be gathered from its provisions when read with the Civil Code. Article 1207 of the Civil Code states that there is solidary liability when the law or the nature of the obligation requires it. Since the Workmen's Compensation Act was enacted to provide full protection to the employee, the nature of the employers' obligation to pay compensation to the heirs of an employee who died in line of duty must be solidary. This interpretation is necessary to attain the purpose of the law, which is to ensure that compensation is fully paid and not defeated by the insolvency of one of the employers. The Court emphasized that the Act should be interpreted to promote its purpose, and in this case, that purpose is best served by a solidary obligation.
Main Doctrine
Under the Workmen's Compensation Act and relevant provisions of the Civil Code, the liability of business partners for the death of an employee arising out of and in the course of employment is solidary, to ensure full protection to the employee and their dependents.