Villones v. Employees' Compensation Commission
REITERATIONFacts
The Antecedents: Petitioner Sonia Villones filed a claim for compensation benefits due to functional bleeding, which she began suffering from in October 1974 and continued until July 1975. Her claim accrued in October 1974. Procedural History: The Employees' Compensation Commission (ECC) and the Government Service Insurance System (GSIS) adversely resolved her claim under the provisions of the New Labor Code. The Supreme Court, in a prior decision dated February 14, 1980, applied the vested right principle and the provisions of the previous compensation law (Workmen's Compensation Act) to her claim, finding that the ECC committed an error in dismissing the claim. The Petition: The ECC and GSIS filed motions for reconsideration/clarification, seeking to relieve the GSIS from payment and hold the employer solely liable, or to have the claim decided under the New Labor Code, among other contentions. They questioned the jurisdiction of the ECC and GSIS over claims that arose prior to the present law and argued against the application of the Workmen's Compensation Act.
Issue(s)
Whether the Employees' Compensation Commission (ECC) and the Government Service Insurance System (GSIS) have jurisdiction over compensation claims that arose prior to the effectivity of the New Labor Code. Whether claims accruing under the Workmen's Compensation Act, which accrued prior to January 1, 1975, are governed by the ten-year prescriptive period or the March 31, 1975 deadline under the New Labor Code. Whether the GSIS is liable to pay compensation benefits and administrative costs, or if the employer should be solely liable. Whether the GSIS has a right of reimbursement from the employer.
Ruling
The Supreme Court denied the motions for reconsideration/clarification. It directed the Government Service Insurance System (GSIS) to pay the petitioner the decreed award minus administrative fees, without prejudice to the GSIS's right to reimbursement from the petitioner's employer after due hearing.
Ratio Decidendi
On the jurisdiction of ECC and GSIS over claims prior to the New Labor Code: The Court reiterated that the ECC and GSIS have jurisdiction over claims whose causes of action arose during the effectivity of the old Workmen's Compensation Act. These claims must be resolved based on the provisions of the repealed Act, as the ECC is the successor to the defunct Workmen's Compensation Commission for claims accruing prior to the New Labor Code. The respondents' contention that they lack jurisdiction is without merit and repugnant to subsequent positions taken by the GSIS itself in other cases. On the applicable prescriptive period and the vested right principle: The Court affirmed that claims accruing prior to January 1, 1975, are governed by the Workmen's Compensation Act. The ten-year prescriptive period for filing claims under the old Act is a vested right that cannot be impaired by the New Labor Code. The March 31, 1975 deadline under Article 292 of the New Labor Code does not apply to claims that accrued under the Workmen's Compensation Act, as this would render the vested rights of claimants worthless and without a forum for enforcement. The framers of the New Labor Code overlooked these vested rights. On the liability for compensation benefits and administrative costs: The Court reiterated its previous order for the GSIS to pay the petitioner the compensation benefits and medical expenses. However, it found merit in the GSIS's contention that it should not be ordered to pay administrative fees. Therefore, the GSIS was directed to pay the decreed award minus the administrative fees. On the GSIS's right of reimbursement from the employer: The Court approved the GSIS's offered solution, which was also implicitly acquiesced to by the ECC. The GSIS is granted the right to seek reimbursement from the petitioner's employer after due hearing. This ensures that the employer has an opportunity to present defenses, thus avoiding arbitrariness and satisfying due process.
Main Doctrine
Claims for employees' compensation that accrued prior to January 1, 1975, shall be decided under the Workmen's Compensation Act, and the ten-year prescriptive period for filing such claims is recognized as a vested right that cannot be impaired by the New Labor Code.