Republic v. Workmen's Compensation Commission
REITERATIONFacts
The Antecedents: The Philippine Air Force (PAF) contracted with Carlos Pineda for the construction of toilet facilities. Carlos Pineda recruited Nazario Bautista as a laborer. While inside the PAF base, Bautista was injured by a baby tractor owned by the PAF and driven by one of its prisoners. Bautista sustained permanent partial disability in his lower extremities. The PAF provided P900 to Bautista through benefit shows, for which Bautista signed a deed of release and quitclaim. Procedural History: Nazario Bautista filed a claim for compensation with the Department of Labor. The regional office hearing officer rendered a decision for the claimant, which was affirmed with modification by the Workmen's Compensation Commission (WCC). The WCC affirmed its decision en banc. The Petition: The PAF filed a petition for review, arguing that it had no employer-employee relationship with Bautista and that Carlos Pineda was the employer. The PAF also questioned the deduction of the P900 paid to Bautista from the award.
Issue(s)
Whether the Philippine Air Force is the employer of Nazario Bautista under the Workmen's Compensation Act. Whether the P900 voluntarily paid to Nazario Bautista should be deducted from the compensation award.
Ruling
The decision of the Workmen's Compensation Commission is affirmed with the modification that the P900 previously paid to Nazario Bautista should be deducted from the compensation award.
Ratio Decidendi
On the employer-employee relationship: The Court affirmed the WCC's finding that the Philippine Air Force is the statutory employer of Nazario Bautista. Section 39(a) of the Workmen's Compensation Act defines 'employer' to include any person who is virtually the owner or manager of the business carried on in the establishment or place of work, even if there is an independent contractor. The construction of facilities like toilets is tied to the primary function of the PAF in maintaining proper and healthful conditions for its personnel. Furthermore, the entire base was under the control of the PAF's base commander, subjecting Bautista's conduct to military restrictions. Therefore, even if not the direct employer, the PAF is liable as a statutory employer. On the deduction of the P900: The Court held that the P900 should be deducted from the compensation award. The PAF paid this amount for humanitarian reasons, without admitting liability, and secured a deed of release and quitclaim from Bautista. While Bautista now relies on his strict legal rights, it would be unjust to allow him to retain the P900 and also claim full legal compensation, especially since the PAF would not have paid the P900 independently of the legal compensation had it known it would be liable. Equity dictates that the PAF should be relieved from the abuse of its generosity.
Main Doctrine
The Philippine Air Force, as the virtual owner or manager of the construction job, is the statutory employer of a laborer injured while working thereon, even if an independent contractor was hired for the construction, and is liable for compensation. However, a sum voluntarily paid by the employer for humanitarian reasons, without admitting liability, should be deducted from the compensation award.