Marapo v. Philippine Packing Corporation
REITERATIONFacts
The Antecedents: Petitioners, Eunila Marapo and her minor children, filed a claim for death compensation benefits following the death of the deceased. Procedural History: The respondent Commission denied the claim. The Supreme Court, in a decision dated January 31, 1977, reversed the Commission's denial and ordered respondent Philippine Packing Corporation to pay petitioners P6,000.00 as death compensation benefit and P200.00 as burial expenses. The Petition: Petitioners' counsel filed a Manifestation and Motion for Attorney's Fee, praying that the Court's decision be amended to include an award of P620.00, representing 10% of the total award, as attorney's fees pursuant to Section 31 of the Workmen's Compensation Act, as amended.
Issue(s)
Whether the attorney's fee award should be based on the total amount awarded, including burial expenses. Whether the dispositive portion of the Court's decision should be amended to include attorney's fees.
Ruling
The Court granted the motion for attorney's fees, amending its previous decision. It ruled that the attorney's fee award of 10% should be based solely on the principal death compensation benefit of P6,000.00, excluding the P200.00 for burial expenses. The dispositive portion was amended to reflect this, awarding P6,000.00 as death compensation, P200.00 as burial expenses, and P600.00 as attorney's fee.
Ratio Decidendi
On Whether the attorney's fee award should be based on the total amount awarded, including burial expenses: The Court held that the attorney's fee award, as provided by Section 31 of the Workmen's Compensation Act, as amended, should be calculated at 10% of the principal amount adjudged as death compensation benefit. This means the P200.00 allocated for burial expenses should be excluded from the computation base for attorney's fees. The purpose of burial expenses is distinct from the compensation benefit itself, serving as reimbursement for costs incurred. Therefore, the attorney's fee is pegged to the primary award meant for the dependents' sustenance and support. The Court found the motion meritorious in principle but clarified the specific basis for the computation. On Whether the dispositive portion of the Court's decision should be amended to include attorney's fees: The Court granted the amendment to its January 31, 1977 decision. It recognized the entitlement of counsel to attorney's fees under the governing law. The dispositive portion was explicitly amended to include "the further amount of P600.00 as attorney's fee," which represents 10% of the P6,000.00 death compensation benefit. This amendment ensures that the counsel's professional services are compensated in accordance with the statutory provisions, thereby correcting an oversight in the original judgment.
Main Doctrine
The Court clarified that attorney's fees, as provided by Section 31 of the Workmen's Compensation Act, as amended, are to be computed at 10% of the principal award for death compensation benefits. This fee is separate from and does not include the statutory burial expenses, which are reimbursement for actual costs incurred.