Facts:

This case revolves around the petitioners Maria Paz S. Alba and others against Dr. Horacio Bulaong, stemming from a tragic incident on March 12, 1955. On that day, five employees of Dr. Bulaong, including petitioners Gregorio de la Cruz, Pedro C. Bulaong, Pacifico Bulaong, Engracio Alba (husband of Maria Paz S. Alba), and Vicente A. Sebastian (husband of Elisea S. Sebastian), were dispatched to thresh palay, following Dr. Bulaong's explicit orders. They were traveling in a tractor that was towing a threshing machine when they were violently struck by a speeding bus owned by Victory Liner Inc. The collision led to the deaths of Engracio Alba and Vicente A. Sebastian, while the other three employees sustained severe injuries. Following this incident, the survivors and dependents of the deceased filed separate compensation claims against Dr. Bulaong before the Workmen’s Compensation Commission (WCC).

In response, Dr. Bulaong presented three defenses: (a) the claimants were not

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Facts:

Background of the Case

• The petitioners, consisting of five men—three employees (Gregorio de la Cruz, Pedro C. Bulaong, and Pacifico Bulaong) and two dependents of employees (Engracio Alba, husband of Maria Paz S. Alba and Vicente A. Sebastian, husband of Elisea S. Sebastian)—filed claims for compensation.
• The claims arose from an automotive accident involving a collision between a bus of Victory Liner Inc. and a threshing machine operated by a tractor belonging to Dr. Horacio Bulaong, who was the employer of the petitioners.
• The accident occurred on March 12, 1955, while the petitioners were en route to Barrio Baringan, Malolos, Bulacan, on specific orders from Dr. Bulaong.

Nature of the Incident and Injuries

• The tractor and attached thresher were struck by a speeding bus, causing the machinery to collide and violently throw its occupants from the vehicle.
• As a result of the incident:
• Engracio Alba and Vicente Sebastian died.
• Gregorio de la Cruz, Pedro C. Bulaong, and Pacifico Bulaong sustained physical injuries.

Claims and Procedural History

• Separate claims for compensation were initially filed before the Workmen’s Compensation Commission against Dr. Bulaong, alleging injuries sustained in the course of employment.
• In response, Dr. Bulaong advanced three defenses:
• Asserting that the claimants were not his employees but industrial partners.
• Contending that the injuries were not sustained in the course of employment.
• Arguing that the claims had been extinguished by monetary settlements previously concluded with Victory Liner Inc.
• The Commission’s referee initially overruled the employer's defenses, establishing:
• That the five individuals were indeed employees.
• That the injuries and deaths occurred in the course of employment.
• That compensation should be awarded in the amounts specified in the referee’s report.
• On appeal, the Workmen's Compensation Commissioner absolved Dr. Bulaong from liability based on evidence that:
• Petitioners had received various sums of money from Victory Liner Inc.
• Each claimant executed a written release or waiver that, despite wording reserving their right to claim under the Workmen’s Compensation Act, appeared to elect the third party (Victory Liner Inc.) for their compensation.

The Controversial Settlement and Its Implications

• The written acknowledgment executed by the petitioners included a clause that read:

"And I likewise freely and completely cede and transfer into said Company (Victory Liner Inc.) any right given to me by law against any person or company that should be liable for said accident except my right to claim against Dr. Horacio Bulaong in accordance with and under the Workmen’s Compensation Act."

Issue:

Nature and Status of the Claimants’ Relationship with Dr. Bulaong

• Whether the petitioners were indeed employees or merely industrial partners of Dr. Bulaong.
• The implications of their status on the applicability of the Workmen’s Compensation Act.

Applicability of Section 6 of the Workmen’s Compensation Law

• Whether petitioners’ execution of a written release with an express reservation constituted an election to claim against Victory Liner Inc. instead of the employer.
• Whether accepting third-party compensation without an explicit lawsuit against the third party barred them from a subsequent claim against Dr. Bulaong.

Interpretation of the Written Release with Reservation

• The legal effect of the language in the waiver, particularly the portion reserving the right to claim against Dr. Bulaong.
• Whether such a reservation is enforceable against a party (Dr. Bulaong) who was not a signatory to the document.

Avoidance of Double Compensation

• How to balance the legal intent to prevent double recovery while safeguarding the petitioners’ right to full and just compensation.
• The role of calculating the proper amounts deducting the sums already received from Victory Liner Inc.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)