Republic v. Workmen's Compensation Commission
REITERATIONFacts
1. The Antecedents: Corporal Marcelo Anchez of the Philippine Constabulary, while on guard duty, experienced a mental breakdown and began firing indiscriminately at his fellow soldiers, killing two and wounding another. He was subsequently killed by return fire. His widow and children filed a claim for death benefits under the Workmen's Compensation Act. 2. Procedural History: The claim was initially filed with the Workmen's Compensation Commission (WCC) on February 20, 1967, over a year after the incident. The Philippine Constabulary, through the Solicitor General's office, initially transmitted the claim papers for action and later expressed its intention to controvert the claim, arguing that the death was not work-connected and the claim was unseasonably filed. The WCC, however, granted the claimants full compensation of P6,000.00 plus attorney's fees, without deducting the P3,000.00 already paid under Republic Act 610. The WCC's resolution denying reconsideration was then brought before this Court. 3. The Petition: The Republic of the Philippines, as petitioner, seeks review of the WCC's resolution. The petition presents two alternative prayers: first, to reverse the WCC's decision and dismiss the claim entirely, asserting the death was not compensable; and second, if the death is deemed compensable, to deduct the P3,000.00 already paid under Republic Act 610 from the total award. The petitioner argues that the claim was not properly controverted by the government and that the prior payment under RA 610 should be deducted to avoid double compensation.
Issue(s)
Whether the death of Corporal Marcelo Anchez is compensable under the Workmen's Compensation Act. Whether the P3,000.00 paid to the respondents-claimants under Republic Act 610 should be deducted from the total award made under the Workmen's Compensation Act.
Ruling
The resolution of the Workmen's Compensation Commission is modified. The P3,000.00 previously received by the respondents-claimants under Republic Act 610 shall be deducted from the total award made to them under the Compensation Law. The claim for compensation is deemed valid.
Ratio Decidendi
On the compensability of Corporal Anchez's death: The Court held that the incident occurred within the premises of the 137th PC Company in Imus, Cavite, during the performance of duty. Although Corporal Anchez acted in a fit of insanity, the Court noted that the petitioner failed to file a timely notice of controversion as required by law. The communications from the Acting Chief of Constabulary and the Solicitor General did not constitute a valid controversion. Therefore, the claim for compensation was deemed validly filed and compensable. On the deduction of benefits received under Republic Act 610: The Court ruled that the P3,000.00 paid under Republic Act 610 should be deducted from the total award under the Workmen's Compensation Act. The Court reasoned that while both laws are social legislations, Republic Act 610 bars payment under other laws, and the Workmen's Compensation Act also excludes other rights and remedies. To prevent double compensation, any amount received under Republic Act 610 must be deducted from the award under the Workmen's Compensation Act. However, if the amount received under Republic Act 610 is less than what can be received under the Workmen's Compensation Act, the difference may still be awarded. The Court clarified that Republic Act 610, as amended, and the Workmen's Compensation Act, as amended by Republic Act 4119, became parallel legislations dealing with the same matter, with the latter being suppletory to the former. This allows beneficiaries to avail of either law, but a full recovery under one bars benefits under the other, and any recovery less than the full amount under one may be augmented by the other.
Main Doctrine
The amount received by claimants under Republic Act No. 610 should be deducted from the total award made to them under the Workmen's Compensation Act, as amended, to prevent double compensation, unless the benefits under Republic Act No. 610 are less than those under the Workmen's Compensation Act, in which case the difference may be awarded.