Title
Benguet Consolidated, Inc. vs. Social Security System
Case
G.R. No. L-19254
Decision Date
Mar 31, 1964
Employee injured on duty received disability benefits under Workmen's Compensation Act; SSS demanded sickness benefits. Court ruled simultaneous recovery allowed under both laws, affirming distinct nature and legislative intent.
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Case Digest (G.R. No. L-19254)

Facts:

  1. Injury and Disability: On September 3, 1960, Lamberto Forosan, an employee of Benguet Consolidated, Inc., suffered an injury while on duty. This injury rendered him unable to work from September 3 to October 8, 1960.
  2. Payment of Disability Benefits: Benguet Consolidated, Inc. paid Forosan disability benefits under Section 14 of the Workmen's Compensation Act for the period of his injury and disability.
  3. Demand for Sickness Benefits: On October 12, 1960, the Social Security System (SSS), through its regional representative, demanded that Benguet Consolidated, Inc. pay Forosan social security sickness benefits for the same period.
  4. Petition to Countermand Demand: Benguet Consolidated, Inc. filed a petition with the Social Security Commission on December 5, 1960, arguing that the demand for sickness benefits was invalid. The company contended that Section 5 of the Workmen's Compensation Act excludes other remedies or benefits for the same injury.
  5. Respondent's Defense: The SSS argued that the Social Security Act (Republic Act No. 1161, as amended) is a later legislation and its benefits are not precluded by the Workmen's Compensation Act. The SSS also emphasized that social security benefits are distinct and complementary to workmen's compensation benefits.
  6. Social Security Commission's Decision: On September 11, 1961, the Commission dismissed Benguet's petition and ordered the company to pay Forosan the sickness benefits under the Social Security Act. Benguet's motion for reconsideration was denied on October 26, 1961, prompting the appeal.

Issue:

The primary issue is whether an employee can simultaneously recover sickness benefits under the Social Security Act and disability benefits under the Workmen's Compensation Act for the same injury or disability.

Ruling:

The Supreme Court affirmed the resolution of the Social Security Commission, holding that sickness benefits under the Social Security Act may be recovered simultaneously with disability benefits under the Workmen's Compensation Act.

Ratio:

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