Pilipinas Shell Petroleum Corporation of the Philippines v. Herminio De La Rosa
REITERATIONFacts
The Antecedents: Claimant Herminio de la Rosa was employed by petitioner Pilipinas Shell Petroleum Corporation as a laborer. He contracted an illness with symptoms of gradual numbness of the body on May 13, 1969, which was diagnosed as transient ischemic attack secondary to vascular insufficiency after suffering a stroke while working in Butuan City. Despite his illness, he continued working and was transferred to different branches. He was eventually hospitalized and, upon discharge, was given a two-month vacation leave. After the leave, he was separated from service due to his sickness. Procedural History: Upon separation, petitioner paid claimant P15,889.00, which included retirement gratuity and a 'special payment.' Claimant signed a 'Release' document waiving all claims, including Workmen's Compensation benefits. Subsequently, claimant filed a claim for disability compensation under the Workmen's Compensation Act. The Regional Office dismissed the claim, finding that the retirement plan rules were not contrary to law, that claimant waived his rights by choosing the retirement plan, and that he had been paid his salary in full during disability. The Workmen's Compensation Commission reversed this decision, granting disability compensation. The Petition: Petitioner filed a petition for review, arguing that the payment of P15,889.00, which included a 'special payment,' discharged its obligations under the Workmen's Compensation Act, and thus the Commission erred in awarding disability benefits that had allegedly already been received.
Issue(s)
Whether the 'special payment' made by the petitioner to the respondent constituted payment for disability benefits under the Workmen's Compensation Act. Whether the 'Release' document signed by the respondent, waiving all claims including Workmen's Compensation benefits, is valid and binding.
Ruling
The decision of the Workmen's Compensation Commission is AFFIRMED. Petitioner is ordered to pay disability compensation benefits to the private respondent.
Ratio Decidendi
On the issue of whether the 'special payment' constituted disability benefits: The Court held that the payment of P15,889.00 was evidenced by two separate documents: a 'Release' for P10,389.87 for retirement gratuity and a 'Supplementary Release' for P5,500.00 denominated as 'special payment.' While retirement gratuity and disability compensation are distinct benefits, the Court found that the term 'special payment' was vague and did not definitively state it was for disability benefits. The respondent Commission correctly pointed out that if it were for disability benefits, it would have been stated explicitly. This aligns with the ruling in Limos v. Fernandez Hermanos, Inc., where a release document worded in broad terms, without expressly including compensation for illness or resulting disability, did not allow the employer to evade liability under the Workmen's Compensation Act. The Court favored the interpretation that the 'special payment' was a consideration for the involuntary separation, especially since separation pay under the law was not evident. On the validity of the 'Release' document: The Court declared the 'Release' document null and void. Section 7 of Act No. 3428, as amended (Workmen's Compensation Act), expressly prohibits any contract, regulation, or device intended to exempt the employer from all or part of the liability created by the Act. The Court cited Centeno v. WCC and Phil. International Shipping Corp. vs. NLRC in support of this prohibition. Therefore, the petitioner failed to prove that the private respondent was paid the compensation benefits mandated by the WCA, rendering the Release document ineffective in waiving such rights. The Court distinguished the present case from Koppel (Phil.) Inc. v. Javellana, where the agreement clearly stipulated that the amount paid was an advance against any award, unlike the vague 'special payment' in this case. The Workmen's Compensation Act, being a social legislation, requires liberal interpretation in favor of the working man.
Main Doctrine
A 'Release' document executed by an employee, purporting to waive claims for disability benefits under the Workmen's Compensation Act, is null and void pursuant to Section 7 of Act No. 3428, as amended, as it is a prohibited contract intended to exempt the employer from liability.